Ronald Morrell v. Warden, 12f4th626

Four Michigan prisoners (Morrell, Edmonds, Thompson, Kennedy) challenged their sentences under the now-unconstitutional pre-Lockridge Michigan sentencing guidelines because the guidelines required judicial factfinding that increased mandatory minimums.
District courts granted conditional writs, ordering resentencings (following this circuit’s Robinson approach) rather than the State’s requested Crosby-style limited hearing.
The State conceded the Sixth Amendment violation (Alleyne/Lockridge) but argued federal habeas courts should remand only for a Crosby hearing to let state trial courts decide whether they would have imposed a materially different sentence.
The Sixth Circuit consolidated the appeals and reviewed the district courts’ choice of habeas remedy for abuse of discretion.
The panel held district courts acted within their broad habeas-remedy discretion and affirmed the conditional grants of relief ordering resentencing rather than requiring Crosby hearings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district courts abused discretion by ordering full resentencing instead of a Crosby hearing	Petitioners: resentencing cures the Sixth Amendment injury and is within habeas courts’ remedial discretion	State: Crosby hearing is the appropriate, less burdensome remedy and Michigan courts prefer it	No abuse of discretion; district courts may order resentencing to cure the constitutional error
Whether federal habeas courts are bound by Michigan Supreme Court’s Lockridge remedy (Crosby)	Petitioners: federal courts need not follow state court’s chosen remedy; must cure federal constitutional violation	State: comity/federalism requires deference to state court’s Crosby remedy	Federal courts are not bound; comity does not preclude federal remedy selection
Whether concerns of comity/federalism/finality require limiting relief to Crosby	Petitioners: full resentencing can better cure the injury despite greater state resources	State: Crosby saves resources and respects state process	Resource concerns insufficient to show abuse of discretion; remedy chosen to cure violation controls
AEDPA / circuit precedent (Reign/Robinson) effect on remedy	Petitioners: Robinson and other Sixth Circuit decisions support resentencing remedy	State: Reign shows Crosby remand is permissible and should govern	Reign only holds Crosby is not an unreasonable AEDPA result; it does not mandate Crosby in all habeas cases; district courts retain discretion

Alleyne v. United States, 570 U.S. 99 (Sup. Ct. 2013) (facts that increase mandatory minimums must be found by a jury)
People v. Lockridge, 870 N.W.2d 502 (Mich. 2015) (Michigan guidelines unconstitutional; courts should render guidelines advisory and employ Crosby remands)
United States v. Crosby, 397 F.3d 103 (2d Cir. 2005) (procedure for district courts to ask whether a materially different sentence would have been imposed)
Robinson v. Woods, 901 F.3d 710 (6th Cir. 2018) (remedying Michigan Lockridge Sixth Amendment violations via resentencing remand)
Reign v. Gidley, 929 F.3d 777 (6th Cir. 2019) (holding a Crosby remand is not inconsistent with clearly established Supreme Court law under AEDPA)
Ewing v. Horton, 914 F.3d 1027 (6th Cir. 2019) (district courts have broad discretion in crafting habeas remedies)