People of Michigan v. Mark Anthony Abbatoy

CourtMichigan Court of Appeals
DecidedJuly 25, 2024
Docket364852
StatusUnpublished

This text of People of Michigan v. Mark Anthony Abbatoy (People of Michigan v. Mark Anthony Abbatoy) 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. Mark Anthony Abbatoy, (Mich. Ct. App. 2024).

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PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED July 25, 2024 Plaintiff-Appellee,

v No. 364852 Berrien Circuit Court MARK ANTHONY ABBATOY, LC No. 1997-403846-FC

Defendant-Appellant.

Before: BOONSTRA, P.J., and FEENEY and YOUNG, JJ.

PER CURIAM.

This case involves whether the trial court abused its discretion when resentencing defendant, Mark Anthony Abbatoy, who was juvenile at the time of his offense, to serve the maximum-possible term-of-years sentence. In October 1997, a jury convicted Abbatoy of felony murder, MCL 750.316(1)(b), for beating Connie DePalma to death with the help of DePalma’s son. Abbatoy was initially sentenced to life imprisonment without the possibility of parole. However, following the United States Supreme Court’s decisions in Miller v Alabama, 567 US 460, 465; 132 S Ct 2455; 183 L Ed 2d 407 (2012), and Montgomery v Louisiana, 577 US 190, 208-209, 136 S Ct 718; 193 L Ed 2d 599 (2016), the trial court held a Miller hearing, denied the prosecutor’s motion for life without parole, and resentenced Abbatoy in 2021 to a term of 40 to 60 years’ imprisonment.

This Court subsequently vacated Abbatoy’s sentence and remanded for another resentencing because the trial court failed to consider Abbatoy’s youth as a mitigating factor, as required by People v Boykin, 510 Mich 171; 987 NW2d 58 (2022). People v Abbatoy (“Abbatoy I”), unpublished per curiam opinion of the Court of Appeals, issued August 18, 2022 (Docket No. 357766), pp 1-2. On remand, the trial court again resentenced Abbatoy to a term of 40 to 60 years in prison. Abbatoy now appeals his second resentencing and argues that the trial court again failed to properly consider his youth at the time of the offense as a mitigating factor. Abbatoy further contends that the trial court overemphasized the nature of the offense while imposing a maximum term-of-years sentence, particularly when every other sentencing factor weighed in favor of mitigation. He also requests that any further resentencing be before a different judge.

-1- Boykin requires that the trial court consider a juvenile defendant’s youth, and a court need not articulate on the record its particular bases for doing so. While there is no particular articulation requirement related to the consideration of youth, there continues to be a requirement that sentencing judges justify their sentence sufficiently to allow for appellate review. People v Copeland, ___ Mich App ___ , ___ ; ___ NW 3d ____ (2024) (Docket No. 363925); slip op at 12, citing Boykin, 510 Mich at 194 (“The trial court was only required to justify its sentence in a manner sufficient for appellate review.”). We do not take issue with the amount of justification provided by the trial court here. Nevertheless, the justification provided demonstrates that the trial court affirmatively misunderstood this Court’s prior ruling and instruction on remand, and erred in applying Boykin to the instant facts. We therefore vacate Abbatoy’s sentence and remand for resentencing consistent with this opinion.

I. BACKGROUND

This Court previously summarized the facts underlying Abbatoy’s conviction as follows:

This case arises out of the beating death of the victim on May 7, 1997, in Bridgman, Michigan. According to trial testimony, on that afternoon, [Abbatoy] was with [Anthony] DePalma. They were both 17 years old. Earlier in the day, [Abbatoy] told DePalma that he planned to run away to California, and DePalma suggested that they steal his mother’s car and drive there. DePalma went into his house and stole the victim’s car keys, then went to a nearby restaurant with [Abbatoy] to discuss their plan. Assuming that the victim would immediately call the police when [Abbatoy] and DePalma took her car, the two planned to knock her out with a shovel so they could be farther away before the authorities were notified of the theft. With this as the plan, [Abbatoy] and DePalma returned to DePalma’s house and found the victim in the garage. [Abbatoy] hit the victim in the head with a shovel three times, and she fell down to the ground. Believing the victim was knocked out, [Abbatoy] left the garage, but then heard a noise and realized that the victim had gotten up and went into the house. [Abbatoy] chased after the victim, kicked down the door to the house, and followed the victim upstairs, where he saw her on the phone. Afraid she was calling 911, [Abbatoy] ripped the phone off the wall, then repeatedly hit the victim on the head with the shovel until she fell to the floor. [Abbatoy] maintained at both his trial and [a] Miller hearing that the victim was still breathing when he left her. At [Abbatoy]’s trial, he testified that he laid the shovel next to the fallen victim and went downstairs, and told DePalma that if he wanted his mother dead, he would have to do it himself. According to [Abbatoy], after that, DePalma went upstairs, and returned a short time later with the shovel. The forensic pathologist at [Abbatoy]’s trial testified that the victim’s cause of death was cranial cerebral trauma (severe head injuries). The victim suffered 10 lacerations on the back and top of her head, and three of those wounds penetrated her skull.

[Abbatoy] and DePalma were tried at the same trial with separate juries. They were both convicted of first-degree felony murder and sentenced [to life imprisonment without the possibility of parole]. [Abbatoy I, unpub op at 2.]

-2- In 2016, following Miller and Montgomery, the prosecution moved to resentence Abbatoy to life without parole. After holding a two-day Miller hearing, the trial court denied that motion and set a date for resentencing. The trial court resentenced Abbatoy to 40 to 60 years in prison.1 This Court later vacated Abbatoy’s sentence and remanded for resentencing because “although the trial court was not required to articulate on the record how [Abbatoy]’s youth affected its decision,” it was “not apparent that the trial court considered [Abbatoy]’s youth at the time of the offense . . . , and even if the court did, it is not apparent that the court treated [Abbatoy]’s youth as a mitigating factor.” Abbatoy I, unpub op at 1-2.

The panel in this Court’s prior opinion observed that “the trial court focused almost exclusively on the horrific nature of [Abbatoy]’s crime, and nothing about that discussion suggested that the trial court was considering [Abbatoy]’s youth and its attendant circumstances.” Id. at 4. Accordingly, this Court vacated Abbatoy’s sentence and remanded “for resentencing in light of Boykin.” Id. at 5.

The panel also addressed other claims that Abbatoy raised on appeal because those claims were “likely to arise again during his resentencing.” Id. at 5. First, the panel considered Abbatoy’s argument that the evidence did not support the trial court’s conclusion that he inflicted the fatal blows to the victim. The panel disagreed, concluding that although “the police officer who testified on behalf of the prosecution at [Abbatoy]’s Miller hearing testified that he could not determine who issued the blow that resulted in the victim’s death, there [was] evidence in the record supporting the trial court’s conclusion that [Abbatoy] inflicted a majority of the blows that resulted in the victim’s death.” Id. Finally, the panel rejected Abbatoy’s argument that the trial court erred by imposing a sentence with a minimum term that was 13 years longer than the sentence imposed on DePalma because they were similarly situated codefendants. The panel explained that Abbatoy was not similarly situated to DePalma because the court reasonably found that Abbatoy inflicted the majority of the blows that caused the victim’s death. Id.

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Related

People v. Snow
194 N.W.2d 314 (Michigan Supreme Court, 1972)
Miller v. Alabama
132 S. Ct. 2455 (Supreme Court, 2012)
Montgomery v. Louisiana
577 U.S. 190 (Supreme Court, 2016)
People v. Hyatt
891 N.W.2d 549 (Michigan Court of Appeals, 2016)
People of Michigan v. William Lawrence Rucker
919 N.W.2d 802 (Michigan Court of Appeals, 2018)
People v. Jamison
807 N.W.2d 427 (Michigan Court of Appeals, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
People of Michigan v. Mark Anthony Abbatoy, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-of-michigan-v-mark-anthony-abbatoy-michctapp-2024.