In People v. Williams, the Court of Appeals considered whether a sentencing court's scoring decisions were clearly erroneous. Under the sentencing guidelines, the court must 'score' certain variables of a crime, including the nature of the offense and the criminal history of the defendant, on a point scale dictated by the Criminal Code. In this case, the defendant was convicted of second-degree home invasion and sentenced to 29 months of incarceration. On appeal, the defendant challenged the trial court's scoring decisions with regard to both the offense and prior record variables.
The Criminal Code requires a sentencing court to consider whether a crime resulted in psychological injury to its victim and to give a score of ten (10) if the crime caused serious psychological injury that requires or may require professional treatment. The defendant argued that the trial court erred when it gave him a score of ten because the court had no basis to conclude that his victim suffered serious psychological injury. The Court of Appeals disagreed, holding that the victim's statements about feeling angry, hurt, violated, and frightened on his Victim Impact Statement were sufficient to support the trial court's score.
The Court of Appeals also rejected the defendant's claim that the trial court erred in giving him a score of twenty-five (25) for his prior record. Under the Criminal Code, twenty-five points should be scored if a defendant has a prior high-severity felony conviction, including a conviction for first-degree home invasion. In 2005, the defendant was found responsible for first-degree home invasion but, as an alternative to a conventional criminal conviction and sentence, he served a term as a youthful trainee under the Holmes Youthful Trainee Act. Relying on a previous Court of Appeals opinion, the defendant argued that his term as a youthful trainee was not a 'conviction' for purposes of the prior record sentencing variable. Again, the Court of Appeals disagreed. Although the Court had ruled in 1996 that an assignment to youthful trainee status did not constitute a conviction for purposes of the sentencing guidelines, the Michigan Legislature amended the Criminal Code in 1998 to include youthful trainee status in its definition of 'conviction.' The Court ruled that the amended statutory definition was controlling and, therefore, the trial court's score was proper.