Justia Criminal Law Opinion Summaries

A jury convicted Defendant-Appellant Drew Peltola on drug possession charges. The trial court considered Defendant's prior criminal history ("prior record variables" or PRVs), and calculated his sentence to be in the five to twenty-three month range, with a statutory minimum at twenty years. Because defendant had a prior conviction for a controlled substance, the trial court applied a sentence enhancement. As a result, the court doubled both the minimum and maximum sentences for each conviction and sentenced defendant within the enhanced guidelines range to concurrent terms of 4 to 40 years' imprisonment. Defendant unsuccessfully appealed the trial court's scoring of his PRVs. The question before the Supreme Court involved whether the trial court miscalculated Defendant's sentence based on its scoring of the PRVs. Upon consideration of the trial record and the applicable legal authority, the Supreme Court found that the trial court's enhancing of Defendant's sentence range was authorized by Michigan law. Accordingly, the Court affirmed the trial court's decision and Defendant's sentence.