People v. Barnes, 917 N.W.2d 577

Timothy Barnes was convicted of second-degree murder in 2002; direct appeal and an initial postconviction motion were denied and appeals exhausted.
Barnes filed a successive motion for relief from judgment arguing he should be resentenced because Michigan’s legislative sentencing guidelines were mandatory at his sentencing but later held advisory in People v. Lockridge.
Trial court denied the successive motion as barred by MCR 6.502(G)(1) (one postconviction motion rule); Barnes argued his motion fit the exception for a retroactive change in law (MCR 6.502(G)(2)).
The core legal question was whether Lockridge (which relied on Alleyne) announces a new rule that must be applied retroactively on collateral review in Michigan.
The Court analyzed federal retroactivity principles (Teague framework as discussed in Montgomery) and Michigan’s state-law retroactivity test from People v. Hampton (purpose, reliance, administration of justice).
The Court concluded Lockridge announced a new procedural rule but that it is not retroactive on collateral review under either federal (Teague) or Michigan (Hampton) standards; relief was denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Lockridge/Alleyne is a new rule	Barnes: Lockridge changes sentencing law and should apply retroactively to permit resentencing	State: Lockridge/Alleyne are new but not retroactive; successive motion barred	Lockridge/Alleyne are new rules but not retroactive on collateral review; successive motion denied
Whether Alleyne/Lockridge are substantive rules under Teague that must be retroactive	Barnes: change to judge-found facts affects sentencing and merits retroactivity	State: Rule alters sentencing procedure, not primary conduct or a class-based punishment rule	Not substantive under Teague; no retroactive federal application
Whether rule is a "watershed" procedural rule under Teague	Barnes: procedural change could affect fairness of sentencing	State: Rule does not affect accuracy of conviction or fundamental fairness of trial	Not a watershed rule; no Teague exception applies
Whether Michigan’s state-law retroactivity (Hampton) requires retroactive relief	Barnes: Michigan should provide relief under state-law retroactivity	State: Purpose, reliance on mandatory guidelines, and administration implications favor prospective application	Under Hampton factors, Lockridge applies only prospectively on collateral review

Alleyne v. United States, 570 U.S. 99 (2013) (held facts increasing mandatory minimum must be found by jury)
People v. Lockridge, 498 Mich. 358 (2015) (held Michigan’s mandatory guidelines system unconstitutional; guidelines now advisory)
Teague v. Lane, 489 U.S. 288 (1989) (framework limiting retroactive application of new rules on federal collateral review)
Montgomery v. Louisiana, 577 U.S. 190 (2016) (explained Teague exceptions: substantive rules and watershed procedural rules)
People v. Hampton, 384 Mich. 669 (1971) (Michigan state-law test for retroactivity: purpose, reliance, administration of justice)
People v. Drohan, 475 Mich. 140 (2006) (prior Michigan precedent applying pre-Alleyne sentencing precedent)
Schriro v. Summerlin, 542 U.S. 348 (2004) (Teague exceptions described; limitations on retroactivity for procedural rules)
Reynoldsville Casket Co. v. Hyde, 514 U.S. 749 (1995) (discussion of retroactivity and when cases are considered closed)