Michigan v. Bonilla-Machado
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Three issues before the Supreme Court in this case arose from events that occurred in November 2007 while Defendant Johnny Bonilla-Machado was serving time at a correctional facility in Ionia. Defendant was there for unarmed robbery and attempted carjacking. While in his cell, Defendant assaulted two corrections officers by overflowing his toilet and splashing the water on the corrections officers as they made their respective rounds. Defendant was charged with two counts of assaulting a prison employee and found guilty by a jury on both counts. Defendant did not testify at his trial. The maximum sentence for assaulting a prison employee was five years. The trial court could enhance the sentence for subsequent felony convictions by not more than one-and-one-half times the statutory maximum. The trial court indicated that it was "bound" to enhance the sentences, and sentenced Defendant as a second-offense habitual offender to concurrent terms of 30 to 90 months for each conviction. Defendant objected to the enhanced maximum sentences. The first issue before the Supreme Court was whether Defendant was coerced by the trial court and his trial counsel to forgo his right to testify. Second, the Court considered whether an offense that was statutorily designated as a "crime against public safety" may also be considered as a "crime against a person" to establish a continuing pattern of criminal behavior for purposes of scoring the offense variable (OV). Finally, the Court considered whether Defendant was entitled to resentencing as a matter of law in light of the trial court's erroneous statement that it was "bound" to enhance Defendant's maximum sentences. Upon review, the Court concluded that there was no evidence that Defendant was coerced to forgo his right to testify. The Court of Appeals erroneously concluded that scoring the assaults of the prison employees were "crimes against public safety," and held that Defendant should be resentenced as to this issue. Finally, the Court concluded that the trial court's "mandated" sentence enhancement comment was in error, but was handled by the Court of Appeals, now making the matter moot. The Court remanded the case back to the trial court to recalculate Defendant's sentence.
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