People v. Laidler
491 Mich. 339
Mich.2012Background
- Defendant and co-perpetrator Holmes attempted to break into a home; homeowner fired in self-defense.
- Holmes was shot and died the same day; defendant was convicted of first-degree home invasion.
- Trial court scored OV 3 at 100 points for death of a victim; Court of Appeals remanded for resentencing.
- Issue on appeal: whether a co-perpetrator can be a 'victim' for OV 3 and thus whether 100 points were proper.
- This Court holds a co-perpetrator may be considered a 'victim' if harmed by the charged party’s actions, and Holmes’s death was caused by defendant’s conduct.
- Concludes OV 3 requires a 'victim' and that the death must be a factual result of the defendant’s actions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether OV 3 requires a 'victim' for scoring | People contends a victim is needed for OV 3 scoring. | Laidler argues OV 3 can apply without a traditional victim. | A victim is required for OV 3 scoring. |
| Whether the death must be causally connected to the defendant’s actions | People asserts death can result from the crime even if not the direct cause. | Laidler asserts there must be causal connection to defendant’s conduct. | Death must be a factual result of the defendant’s actions. |
| Whether a co-perpetrator can be a 'victim' for OV 3 | People argues a co-perpetrator harmed by the crime can be a victim. | Laidler contends a co-offender cannot be a victim under OV 3. | Holmes was a victim; a co-perpetrator may be a victim for OV 3. |
Key Cases Cited
- People v Schaefer, 473 Mich 418 (2005) (discussed causation standards for result in crime)
- People v Albers, 258 Mich App 578 (2003) (victim includes anyone harmed by charged party’s actions)
- Robinson v City of Lansing, 486 Mich 1 (2010) (statutory interpretation regarding language and intent)
- People v Monaco, 474 Mich 48 (2006) (distinct interpretation of victim language across OVs)
- Laidler, 291 Mich App 199 (2010) (dispositive Court of Appeals view on OV 3 victim scope)
- Schaefer, 473 Mich 418 (2005) (discussed causation in defining 'results from' language)