The Michigan Supreme Court ruled on July 29, 2026, that Evan Taylor Armogeda is entitled to resentencing due to errors in the calculation of his sentencing guidelines. The court's decision affects how trial courts handle sentencing in cases where guidelines are incorrectly applied, ensuring defendants are sentenced based on accurate information.
Armogeda was convicted of multiple charges, including assault with intent to commit murder, and was sentenced to 360 months in prison. His sentencing guidelines were initially calculated incorrectly, leading to a dispute over the appropriate range. The ruling emphasizes the importance of accurate sentencing guidelines and the right to resentencing when errors occur.
Background
The case involves Evan Taylor Armogeda, who was convicted by a jury of assault with intent to commit murder, carrying a dangerous weapon with unlawful intent, and third-degree fleeing and eluding. Following his conviction, the trial court imposed a controlling sentence of 360 to 600 months for the assault charge, based on a calculated guidelines range of 270 to 450 months.
After sentencing, Armogeda filed a motion to correct what he claimed was an invalid sentence. He argued that the scoring of certain variables in the sentencing guidelines was incorrect, which would change the applicable range. The prosecution agreed that there were scoring errors but contended that the proper range would be 225 to 375 months. However, the trial court did not resolve the scoring issue and maintained that it would impose the same minimum sentence regardless of the guidelines.
The Court of Appeals affirmed the trial court's decision but remanded the case for correction of the guidelines range. On remand, both parties agreed to amend the scoring of the guidelines, establishing a new range of 171 to 285 months. However, the trial court did not change Armogeda's sentence, leading to further appeals.
The Ruling
The Michigan Supreme Court, in a decision led by Chief Justice Megan K. Cavanagh, ruled that Armogeda is entitled to resentencing. The court stated, "When a defendant’s sentence is based on inaccurate information and falls outside the corrected guidelines range, the defendant is entitled to resentencing, even if the trial court has indicated that it would impose the same sentence on remand." This ruling reinforces the principle that defendants must be sentenced based on accurate information.
The court clarified that the trial court's refusal to reconsider the sentence in light of the corrected scoring was an error. The opinion emphasized that the trial court must rescore the guidelines and consider the corrected range when imposing a new sentence. The court also noted that while the trial court could impose the same sentence, it must do so based on accurate information.
Impact
This ruling has significant implications for sentencing practices in Michigan. It establishes that defendants have a right to resentencing when their sentences are based on incorrect guidelines, regardless of whether the trial court believes it would impose the same sentence. This decision ensures that all defendants are treated fairly and that their sentences reflect accurate assessments of their circumstances and offenses.
The ruling also reinforces the need for trial courts to adhere strictly to guidelines when determining sentences. It highlights the importance of accurate information in the sentencing process and the necessity for courts to provide a clear rationale for any departures from the guidelines.
What's Next
The case is remanded to the trial court for resentencing. The trial court will need to recalculate the sentencing guidelines based on accurate information and consider the new range when determining Armogeda's sentence. It remains to be seen whether the trial court will impose a different sentence or maintain the original one.