Background
A jury convicted Evan Taylor Armogeda of assault with intent to commit murder, carrying a dangerous weapon with unlawful intent, and third-degree fleeing and eluding. Based on a calculated minimum sentencing-guidelines range of 270 to 450 months for the assault conviction, the trial court imposed a controlling sentence of 360 to 600 months’ imprisonment.
Armogeda moved to correct an invalid sentence, challenging the scoring of Prior Record Variable 2 and Offense Variable 12. Rather than determine the correct scores, the trial court denied relief after stating that 360 months was the lowest appropriate minimum sentence regardless of the applicable range. The Court of Appeals affirmed the sentence but remanded to correct the scoring and presentence report. On remand, the parties stipulated that both variables should receive zero points, producing a corrected range of 171 to 285 months, but Armogeda’s sentence remained unchanged.
The Court’s Holding
The Michigan Supreme Court held that a defendant whose sentence was based on an incorrectly calculated guidelines range and exceeds the corrected range is entitled to resentencing, even if the trial court previously said it would impose the same sentence. The Court reaffirmed People v. Francisco and held that its resentencing rule remains compatible with the advisory-guidelines system established by People v. Lockridge.
Although the guidelines are advisory, sentencing courts must accurately score them, calculate the applicable range, and consider that range when selecting a sentence. Because the trial court did not resolve the scoring dispute or reconsider Armogeda’s sentence using the corrected range, the Supreme Court reversed the Court of Appeals in part and remanded for resentencing. The trial court may impose the same sentence again if it finds the sentence reasonable and proportionate, but it must explain any departure from the corrected range.
Key Takeaways
- Michigan’s advisory sentencing guidelines must still be accurately scored, calculated, and considered.
- A trial court’s statement that it would impose the same sentence does not avoid resentencing when the original sentence exceeds the corrected guidelines range.
- On remand, the court may reimpose the same sentence, but any departure must be reasonable, proportionate, and supported by articulated reasons.
Why It Matters
The decision confirms that Lockridge did not displace Francisco’s protection against sentencing based on an inaccurate guidelines range. Accurate calculation remains essential both to individualized sentencing and to meaningful appellate review.
The ruling does not require a lower sentence for Armogeda. It requires a new sentencing decision made with the correct 171-to-285-month range as the benchmark and an adequate explanation if the court again selects a 360-month minimum.