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256 Mich. App. 165

662 N.W.2d 101

People v. McDaniel

Michigan Court of Appeals

Decided May 29, 2003

Michigan Court of Appeals · decided 2003-05-29

Cited by 6 later decisions — most recently March 2006

6 state decisions

Key passage — most relied on by later courts

“reflects that no particular period is referred to in the statute. Had the Legislature intended the meaning defendant assumes, the statute would refer to”

quoted by 1 later decision, including People v. Francisco

“[A]ll crimes within a 5-year period, including the sentencing offense, shall be counted regardless of whether the offense resulted in a conviction.”

quoted by 1 later decision, including People v. Francisco

Good law ✅— No negative treatment on recordhow we know

Decided 2003-05-29

View the full empirical analysis of this case →

Donofrio, J.

¶1(dissenting). I concur in part and respectfully dissent in part. I would affirm defendant Derrick D. McDaniel’s conviction for the same reasons as the majority; however, I would remand the case to the trial court for resentencing.

¶2Defendant raises a challenge to the scoring of his sentence under the sentencing guidelines. Defendant argues that the trial court misscored offense variable 13 (ov 13) regarding his first-degree retail fraud conviction. First-degree retail fraud is a class E felony against property, requiring scoring of ov 13, continuing pattern of criminal behavior. MCL 777.16r; MCL 777.22(2); MCL 777.43(1). In scoring OV 13, the court is required to score ten points where “[t]he offense was part of a pattern of felonious criminal activity involving 3 or more crimes against a person or property.” MCL 777.43(c). The statute allows consideration of “all crimes within a 5-year period, including the sentencing offense . . . regardless of whether the offense resulted in a conviction.” MCL 777.43(2)(a).

¶3I believe that defendant was incorrectly scored under subsection MCL 777.43(c). The majority agrees *174with the prosecutor’s interpretation of the statute and asserts that “[t]he use of the indefinite article ‘a’ reflects that no particular period is referred to in the statute.” I disagree. The language at issue states that “all crimes within a 5-year period, including the sentencing offense, shall be counted.” MCL 777.43(2)(a) (emphasis added). Because the word “shall” is used, I find it is impossible for any five-year period that does not include the sentencing offense to be considered. Contrary to the majority’s interpretation of the statute, my reading of the statutory language clearly precludes consideration of a five-year period that does not include the sentencing offense. Crimes outside the five-year period contemplated are already considered in the prior record variables.

¶4My review of defendant’s criminal record does not indicate any three or more felonies occurring within the immediate five-year period; thus, scoring ten points was inappropriate. This scoring error resulted in an elevated guidelines recommendation. MCL 777.21(3)(c); MCL 777.66.

¶5I believe that defendant has established error that resulted in his incarceration beyond the appropriate minimum range under the guidelines, and I would remand for correction of the guidelines scoring error and resentencing.

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