Michigan v. Lockridge (Opinion - Leave Granted)Annotate this Case
Rahim Omarkhan Lockridge was convicted by jury of involuntary manslaughter for the death of his wife.His minimum sentence range calculated under the sentencing guidelines was 43 to 86 months. The trial court concluded that there were factors not accounted for in scoring the guidelines, including a probation violation, killing his wife in front of their three children, leaving the children at home with their mother dead on the floor, and prior domestic violence. Citing these as reasons to depart from the minimum sentence range, the court sentenced defendant to a term of 8 years (96 months) to 15 years (the statutory maximum sentence). Defendant appealed, challenging both the scoring of the guidelines and the trial court’s decision to exceed the guidelines minimum sentence range. While his case was pending in the Court of Appeals, the United States Supreme Court decided "Alleyne v United States," (133 S Ct 2151 (2013)), which extended the rule of "Apprendi v New Jersey," (530 US 466 (2000)), and held that a fact that increases either end of a defendant’s sentencing range must have been admitted by the defendant or found by the jury beyond a reasonable doubt. After allowing defendant to file a supplemental brief challenging the guidelines scoring on "Alleyne" grounds, the Court of Appeals affirmed defendant’s sentence in three separate opinions and rejected the Alleyne challenge. The Michigan Supreme Court granted defendant's application to address the constitutional question presented by his Alleyne challenge. The Court found that in this case, defendant’s guidelines minimum sentence range was irrelevant to the upward departure sentence he ultimately received. Accordingly, the Court held that he could not show the prejudice necessary to establish plain error under "Michigan v. Carines," (597 NW2d 130 (1999)), and affirmed his sentence.