People v. Butler, 892 N.W.2d 6

Defendant pleaded guilty to second-degree home invasion for a 2014 offense and was sentenced within the guidelines to 3–15 years.
Defendant has an extensive record from the 1980s–1990s but (aside from an anomalous 2006 conviction arising from a 1993 offense) had no convictions between 2001 and 2012.
The 2006 conviction was not a type of misdemeanor normally scorable under PRV 5 (MCL 777.55), but if counted it eliminates any 10‑year gap and raises PRV 5 to 20 points.
MCL 777.50 contains a “10‑year gap” rule that excludes prior convictions from PRV scoring when the defendant was conviction‑free for ten or more years between discharges and subsequent offenses.
The sentencing dispute: whether convictions that are not scorable under PRV rules may nonetheless be considered when applying the MCL 777.50 ten‑year gap.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a prior conviction that is not scorable under PRV rules may nonetheless defeat the 10‑year gap of MCL 777.50	The prosecution/majority: the plain word “conviction” in MCL 777.50 includes any conviction; any conviction within ten years defeats the gap	Defendant: only convictions that are scorable under PRV rules (MCL 777.55) should count to determine the 10‑year gap; unscorable minor misdemeanors should not revive earlier history	Held for prosecution/majority: any prior conviction — even if not scorable under PRV 5 — counts for the 10‑year gap; trial court scoring affirmed

People v Reyna, 184 Mich. App. 626 (ten‑year rule can be defeated by any conviction; focus is on being conviction‑free)
People v Stephan, 241 Mich. App. 482 (in pari materia doctrine: related statutes should be read together to effect legislative purpose)
People v Cannon, 481 Mich. 152 (standard of review for statutory interpretation in sentencing guidelines)
People v Smith, 482 Mich. 292 (legislative sentencing guidelines enacted to facilitate proportionate sentencing)