People of Michigan v. Jonathan Belton

CourtMichigan Court of Appeals
DecidedApril 17, 2026
Docket367648
StatusUnpublished

This text of People of Michigan v. Jonathan Belton (People of Michigan v. Jonathan Belton) is published on Counsel Stack Legal Research, covering Michigan Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People of Michigan v. Jonathan Belton, (Mich. Ct. App. 2026).

Opinion

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to revision until final publication in the Michigan Appeals Reports.

STATE OF MICHIGAN

COURT OF APPEALS

PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED April 17, 2026 Plaintiff-Appellee, 3:20 PM

v No. 367648 Oakland Circuit Court JONATHAN BELTON, LC No. 2009-225093-FC

Defendant-Appellant.

Before: RIORDAN, P.J., and GARRETT and MARIANI, JJ.

PER CURIAM.

Defendant appeals by right his resentencing of 40 to 70 years’ imprisonment for his 2010 convictions of first-degree premeditated murder, MCL 750.316(1)(a), and murder of a peace officer, MCL 750.316(1)(c). We affirm.

I. FACTUAL AND PROCEDURAL BACKGROUND

In November 2010, a jury found defendant guilty of one count of first-degree murder, one count of murder of a peace officer, and two counts of possession of a firearm during the commission of a felony (felony-firearm), MCL 750.227b, for offenses he committed following a routine traffic stop when he was 16 years old. The trial court subsequently sentenced defendant to concurrent sentences of mandatory life imprisonment without the possibility of parole (LWOP) for each murder conviction and a term of two years’ imprisonment for each felony-firearm conviction, which were to be served concurrently to one another but consecutively to the murder convictions. Defendant appealed, and this Court affirmed his convictions but remanded to the trial court for resentencing in accordance with the United States Supreme Court’s holding in Miller v Alabama, 567 US 460, 465, 471; 132 S Ct 2455; 183 L Ed 2d 407 (2012), that a mandatory LWOP sentence imposed on juvenile defendants violates the Eighth Amendment and that mitigating qualities of youth must be considered when sentencing a juvenile defendant. People v Belton, unpublished per curiam opinion of the Court of Appeals, issued October 24, 2013 (Docket No. 302107), pp 1, 13-14 (Belton I).

In connection with that prior appeal, this Court detailed the facts underlying defendant’s convictions, see generally id., but to summarize for purposes of this appeal: Defendant was

-1- convicted for fatally shooting Oak Park police officer Mason Samborski in the head with Officer Samborski’s service weapon in the early morning hours of December 28, 2008. Testimony and other evidence at trial established that Officer Samborski had stopped defendant for a traffic violation and, rather than take defendant to the police station, Officer Samborski escorted defendant to an apartment that defendant claimed he lived in. In actuality, defendant had led Officer Samborski to another individual’s apartment in an effort to deceive the officer. Officer Samborski eventually became suspicious and indicated that he would take defendant to jail, so defendant began to run away. Officer Samborski gave chase and attempted to restrain defendant; defendant resisted, and a struggle ensued. During the struggle, Officer Samborski fell down a stairway in the apartment building, hit his head, and sustained head trauma significant enough to impair or incapacitate him. According to the prosecution’s theory of the case and supporting evidence, defendant then grabbed Officer Samborski’s service weapon while the officer was lying on the ground, pointed the gun at his head, and shot him from less than an inch away. Defendant then fled with Officer Samborski’s service weapon and cell phone, which he later used to make multiple phone calls. Neither the gun nor the cell phone was ever recovered. Defendant’s theory of the case was that the shooting occurred accidentally during the struggle between him and the officer, and defendant himself did not shoot the gun.

As noted, defendant was convicted by a jury and sentenced to mandatory LWOP, and then he appealed to this Court. See id. at 1-2. While his appeal was pending, the United States Supreme Court issued its decision in Miller, and both defendant and the prosecution recognized that defendant’s case had to be remanded for resentencing in accordance with that decision. Id. at 13- 14. This Court agreed and remanded for resentencing on that basis, but otherwise rejected defendant’s challenges on appeal and affirmed his convictions. Id. at 14.

On remand, the prosecution filed a motion pursuant to MCL 769.25(3) requesting that defendant be resentenced to LWOP. The prosecution argued that LWOP was warranted because, despite defendant’s young age at the time of the offense, the circumstances surrounding the murder were “especially heinous,” and defendant demonstrated a lack of remorse, a poor prison record, and a low potential for rehabilitation. Defendant opposed the prosecution’s motion and asked that the court conduct a hearing pursuant to MCL 769.25(6) to consider the mitigating qualities of youth as described in Miller and instead sentence him to a term of years in accordance with MCL 769.25(9).

After several hearings and various delays on remand,1 defendant was resentenced in November 2022. Following a four-day Miller hearing to determine whether an LWOP sentence or a term-of-years sentence was appropriate for defendant, the court resentenced defendant to term- of-years sentence of 40 to 70 years. This appeal followed.2

1 While the COVID-19 pandemic contributed to some of the time delay, much of it was due to the release of new caselaw addressing juvenile-sentencing and Miller-resentencing issues, which were rapidly evolving areas of law while this case was pending on remand. 2 Shortly after defendant filed his brief on appeal with this Court, he also filed a motion to remand to the trial court for an evidentiary hearing regarding his ineffective-assistance claim discussed

-2- II. MILLER RESENTENCING

On appeal, defendant argues that he is entitled to resentencing on several related but distinct grounds. Specifically, defendant argues that: (1) the trial court did not properly consider his youth as a mitigating factor as required by Miller and its progeny; (2) his term-of-years sentence imposed at resentencing was disproportionate and therefore unreasonable in light of Miller and its progeny; (3) his term-of-years sentence amounted to an unconstitutional de facto life sentence; and (4) his 70-year maximum sentence impermissibly exceeded the 60-year cap on maximum sentences imposed by the statutory scheme that governed his resentencing. We do not see grounds for relief in defendant’s arguments.

A. CONSIDERATION OF YOUTH AND PROPORTIONALITY OF SENTENCE

Defendant first argues that the trial court did not properly consider his youth as a mitigating factor at resentencing as required by Miller and the Michigan Supreme Court’s decision in People v Boykin, 510 Mich 171; 987 NW2d 58 (2022). Relatedly, defendant argues that his term-of-years sentence imposed at resentencing was disproportionate and therefore unreasonable in light of Miller and Boykin.

We review a sentence for reasonableness. People v Posey, 512 Mich 317, 359-360; 1 NW3d 101 (2023). “[T]he proper inquiry when reviewing a sentence for reasonableness is whether the trial court abused its discretion by violating the ‘principle of proportionality’ set forth in People v Milbourn, 435 Mich 630, 636; 461 NW2d 1 (1990), ‘which requires sentences imposed by the trial court to be proportionate to the seriousness of the circumstances surrounding the offense and the offender.’ ” People v Steanhouse, 500 Mich 453, 459-460; 902 NW2d 327 (2017).

“As recognized by our Supreme Court in Boykin, the holding in Miller stands for the proposition that youth matters in sentencing decisions and that the mitigating characteristics of youth must be considered by a [sentencing] court.” People v Echols, ___ Mich App ___, ___; ___ NW3d ___ (2025) (Docket No. 370709); slip op at 3-4 (cleaned up); see also Boykin, 510 Mich at 192.

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People of Michigan v. Jonathan Belton, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-of-michigan-v-jonathan-belton-michctapp-2026.