Michigan v. Laidler (Opinion)
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The issue before the Supreme Court was whether the death of a coperpetrator of a crime may be scored under offense variable (OV) 3, MCL 777.33, which concerns "physical injury to a victim." Upon review, the Court concluded that a coperpetrator is properly considered a "victim" for purposes of OV 3 when he or she is harmed by the criminal actions of the charged party, in this case, Defendant Marteez Laidler. Because the Court concluded that the coperpetrator's death constituted such a harm, the Court reversed in part the judgment of the Court of Appeals and reinstated Defendant's
sentence. The trial court properly assessed 100 points for OV 3 because the coperpetrator was harmed by the criminal actions of Defendant.
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