Michigan v. Huston
Annotate this CaseAt issue before the Supreme Court was whether a trial court properly assessed fifteen points for an "offense variable" (OV) to Defendant Cecil Huston sentence when he engaged in "predatory conduct to exploit […] a vulnerable victim." Defendant was charged with armed robbery and carjacking when he and another robbed a female victim in a shopping mall parking lot. Contrary to the Court of Appeals' holding, The Supreme Court held that in order to assess 15 points for the OV, Defendant's pre-offense conduct only had to be directed at "a victim"--not a specific victim-- and the victim did not have to be inherently vulnerable. Instead, a defendant's "predatory conduct" alone can create or enhance a victim's "vulnerability." In this case, Defendant engaged in "predatory conduct" to "exploit a vulnerable victim" because Defendant and his accomplice lain in wait, armed with two BB guns and a knife, and hid from the victim who was by herself at night in an otherwise empty parking lot. Because the trial court properly assessed fifteen points for the OV, the Supreme Court reversed the appellate court's decision and reinstated the trial court's judgment and sentence.
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