Robinson v. Woods, No. 16-2067 (6th Cir. 2018)
Annotate this CaseRobinson and two cohorts sold the victim a large amount of crack cocaine on credit, beat the victim when he was unable to pay, and, extorted from the victim’s parents for roughly $1,000. A Michigan jury convicted Robinson of extortion, delivery of a controlled substance, unlawful imprisonment, and aggravated assault. Based on his Presentence Investigation Report, the sentencing court scored multiple variables that went beyond the elements of the offenses for which Robinson was convicted, including the number of victims and exploitation of a vulnerable victim, resulting in higher minimum-sentence ranges than would have been warranted without those judge-found facts. The judge imposed concurrent sentences, the longest being 38-480 months for the delivery-of-a-controlled-substance conviction. The Michigan Court of Appeals affirmed. The Sixth Circuit conditionally granted habeas relief, limited to Robinson’s sentence. The Supreme Court has interpreted the Sixth Amendment’s jury guarantee to mean that “[a]ny fact that, by law, increases the penalty for a crime . . . must be submitted to the jury and found beyond a reasonable doubt,” Alleyne v. United States (2013). The Michigan court violated Robinson’s Sixth Amendment right by using judge-found facts to score sentencing variables that increased his mandatory minimum sentence,“ which “was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court.”
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