Chase v. MaCauley, No. 19-1202 (6th Cir. 2020)
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Chase was convicted of kidnapping, first-degree criminal sexual conduct, unlawful imprisonment, and assault with a dangerous weapon. In 2013, the Michigan court imposed two consecutive terms of 25-80 years’ imprisonment on the criminal sexual conduct counts, to be served concurrently with terms for the other counts. Michigan’s sentencing guidelines allowed a sentencing court to depart from the guidelines’ mandatory sentencing ranges upon a showing of “a substantial and compelling reason,” using “prior record variables” and “offense variables.” In Chase’s case, the court increased Chase’s minimum sentencing range based on offense variables that had not been found by the jury, such as serving as a “leader” and causing bodily injury and serious psychological injury requiring professional treatment.
Days after Chase’s sentencing, the U.S. Supreme Court held, in “Alleyne,” that the Sixth Amendment requires any fact that increases a defendant’s mandatory minimum sentence be found by a jury, not a judge. Chase did not raise an “Alleyne” claim on direct appeal. The Michigan Supreme Court did not determine that Alleyne rendered its sentencing scheme unconstitutional until 2015.
The Sixth Circuit granted Chase habeas relief, excusing the procedural default. Because there is a reasonable probability that, but for his appellate counsel’s error, Chase would have received relief from the Michigan Supreme Court, he has shown prejudice. A decision upholding the sentencing court’s use of judge-found facts to raise Chase’s mandatory minimum sentence would be contrary to clearly established federal law,.
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