Michigan v. Arnold (Opinion - Leave Granted)Annotate this Case
Defendant Lonnie Arnold masturbated in front of an employee at the Monroe Public Library in January 2014. He was charged with aggravated indecent exposure, MCL 750.335a(2)(b), indecent exposure by a sexually delinquent person, MCL 750.335a(2)(c), and also with being a fourth-offense habitual offender, MCL 769.12. He was convicted after a jury trial on both substantive indecent-exposure counts. At sentencing, the Department of Corrections (DOC) recommended defendant serve 225 months to 40 years in prison on the count of indecent exposure by a sexually delinquent person, to be served concurrently with 2 to 15 years on the aggravated indecent-exposure count. At sentencing, defense counsel asked that defendant be given “1 day to life.” The issue this case presented for the Michigan Supreme Court's review was whether individuals convicted of being “sexually delinquent persons” must be given a “1 day to life” prison sentence in accordance with MCL 750.335a(2)(c). The Court concluded that a “1 day to life” sentence has never been required by the statutory scheme, overruling the Court of Appeals’ contrary conclusion in Michigan v Campbell, 894 NW2d 72 (2016), and remanded this case to the Court of Appeals for reconsideration in light of its conclusion.