The Michigan Supreme Court has ordered a new sentencing hearing for Evan Taylor Armogeda, who was convicted of assault with intent to commit murder and other charges. The court's decision, made on July 29, 2026, affects how sentencing guidelines are applied in Michigan, particularly when they are based on inaccurate information.
This ruling is significant because it underscores the importance of accurate sentencing guidelines in ensuring fair treatment for defendants. The court found that Armogeda's original sentence did not align with the corrected guidelines range, thus entitling him to resentencing.
Background
Evan Taylor Armogeda was convicted following a jury trial on several charges, including assault with intent to commit murder (AWIM) and carrying a dangerous weapon with unlawful intent. At his initial sentencing, the trial court imposed a controlling sentence of 360 to 600 months. However, issues arose regarding the scoring of his sentencing guidelines, specifically Prior Record Variable (PRV) 2 and Offense Variable (OV) 12.
After the trial court sentenced Armogeda, he filed a motion to correct what he claimed was an invalid sentence. He argued that the scoring for PRV 2 and OV 12 had been incorrectly calculated, which should have resulted in a lower guidelines range of 171 to 285 months. The prosecution agreed that there had been an error but contended that the correct range should be 225 to 375 months. Instead of addressing these discrepancies, the trial court stated it would impose the same minimum sentence regardless of the guidelines range and denied the motion.
The Court of Appeals later affirmed the trial court's decision but remanded the case for adjustments to the guidelines range based on the correct scoring of PRV 2 and OV 12. On remand, the parties agreed to score PRV 2 and OV 12 at zero points, establishing a new guidelines range of 171 to 285 months. Despite this agreement, the trial court did not change Armogeda's controlling sentence.
The Ruling
The Michigan Supreme Court, led by Chief Justice Megan K. Cavanagh, ruled that Armogeda is entitled to resentencing. The court emphasized that a sentence based on inaccurate information that exceeds the corrected guidelines range necessitates resentencing, even if the trial court indicated it would impose the same sentence regardless of the scoring error.
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." The ruling clarified that the trial court must reconsider the sentence based on accurate information and the corrected guidelines.
The justices unanimously agreed that the trial court had erred by not recalculating the guidelines and considering the corrected range. The court noted that the trial court's failure to do so violated the principles established in previous cases, particularly People v Francisco, which mandates that defendants be sentenced based on accurate guidelines.
Impact
This ruling has broader implications for how sentencing is handled in Michigan. It reinforces the necessity for trial courts to adhere strictly to accurate guidelines when determining sentences. The court's decision ensures that defendants are treated fairly and that their sentences reflect the seriousness of their offenses in relation to the established guidelines.
Moreover, the ruling clarifies that even if a trial court expresses an intention to impose the same sentence regardless of scoring errors, it cannot do so if the sentence exceeds the corrected guidelines range. This sets a precedent that emphasizes the importance of accurate information in sentencing decisions.
What's Next
Following this ruling, Armogeda's case will return to the trial court for resentencing. The court will need to reassess the sentencing variables based on accurate information and the corrected guidelines range. The possibility of appeal remains for any subsequent decisions made during the resentencing process.