People v. Ewing

458 N.W.2d 880, 435 Mich. 443
CourtMichigan Supreme Court
DecidedAugust 14, 1990
Docket84137, (Calendar No. 4)
StatusPublished
Cited by36 cases

This text of 458 N.W.2d 880 (People v. Ewing) is published on Counsel Stack Legal Research, covering Michigan Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Ewing, 458 N.W.2d 880, 435 Mich. 443 (Mich. 1990).

Opinions

AFTER REMAND

Brickley, J.

I am unable to agree entirely with the analysis adopted in the opinions of either Justice Boyle or Justice Archer. I believe that the trial judge was entitled to base his sentence not only on the defendant’s prior conviction, but also on testimony concerning the underlying facts of the prior conviction, a pending charge, and an uncharged offense. The defendant, however, was denied his right to test the accuracy of these allegations regarding his conduct.

For this reason, it is my opinion that this case should be remanded to the trial court. On remand, the sentencing judge should indicate with greater specificity which facts he relied on in imposing sentence. If the judge determines that he relied on allegations against the defendant which did not result in a conviction, then the defendant must be afforded an opportunity to challenge the accuracy of those allegations. If the judge then determines that the accuracy of those facts has not been determined by a preponderance of the evidence, the defendant should be resentenced. Finally, if a resentencing is ordered, the judge will be entitled to rely on testimony containing facts underlying an acquittal which was obtained after the original sentencing in this case, subject to the defendant’s right to dispute the accuracy of that testimony.

i

Defendant Ewing was convicted by a jury of [447]*447first-degree criminal sexual conduct. The opinion for reversal accurately summarizes the testimony given at trial and at the pretrial Golochowicz1 hearing, as well as the appellate history of this case. Post, pp 463-468 (Boyle, J.).

In addition, I observe that the defendant, at the time of sentencing, had pled nolo contendere to the first-degree criminal sexual conduct charge involving complainant No. 1. Following his conviction and sentence in this case, the defendant was acquitted of charges arising from the violent sexual assault alleged by complainant No. 3. He was never charged with the crime alleged by complainant No. 6, which the judge at the Golochowicz hearing described as a "simple assault.”

At the sentencing hearing, the prosecutor urged the court to depart from the guidelines and impose a very lengthy sentence. The prosecutor not only emphasized the defendant’s convictions involving the 1979 assault on complainant No. 1 and in the present case, but also insisted that the court rely on allegations against the defendant which had not resulted in convictions.

The prosecutor vehemently argued that a sentencing judge should be able to make assumptions about a defendant’s guilt of separate criminal charges, and he urged the trial judge to "have . . . the guts to do something more to look beyond the substance of this particular case in the form of it just on the record.”2

The defendant objected on the record, prior to [448]*448the imposition of sentence, to the consideration of arrests or any charged offense not resulting in conviction as evidence of guilt in imposing sentence. The trial court did not respond to the defendant’s objection.3

After hearing from the prosecutor and defense counsel, the trial court explained its decision to depart from the guidelines’ recommended range of ten to twenty years. In imposing a life sentence, the trial judge stated, inter alia:

As a part of this overall process a Golochowicz Hearing was held in which I very vividly had to hear the testimony of other victims who claimed you assaulted them in some manner or form. I had to make that ruling or determination relative to admissibility of similar testimony in this trial.
It’s obvious to me you have carried on a course of conduct involving attacks on young women over a periods [sic] of five years.

II

The judge’s references to the witnesses produced at the Golochowicz hearing and to a "course of conduct” do not clearly identify particular acts of the defendant. To my mind, neither the defendant, [449]*449as suggested by Justice Boyle, nor the trial judge is solely to blame for this ambiguity. The judge has an obligation to articulate reasons for imposing a sentence and to respond to defense challenges to the propriety of using certain information. The defendant, on the other hand, has a duty to raise matters of accuracy and should, as a matter of course, request rulings or findings from the judge when necessary. Here, the defendant clearly objected to the judge’s consideration of alleged criminal acts which did not result in convictions, but he received no ruling or explanation from the judge in response to the objection. It is clear that the judge considered the testimony of the similar acts witnesses. However, it is not clear which allegations presented at the Golochowicz hearing were considered. Under these circumstances, this case should be remanded to the trial court for further development of the sentencing record. First, the trial court should explain with greater specificity which conduct, convictions, or charges played a role in determining the defendant’s sentence. After this is done, the defendant should be given an opportunity to challenge the accuracy of those allegations regarding criminal acts for which no conviction has been obtained and upon which the original sentence was based. If the judge determines that the accuracy of the allegations has not been proven by a preponderance of the evidence, the original sentence should be vacated and the defendant resentenced.

hi

If, on remand, the trial judge determines that acts which did not end in conviction contributed to his sentencing decision, the defendant should be permitted to exercise his right to contest the accu[450]*450racy of those allegations in accordance with the American Bar Association Standards.

In People v Walker, 428 Mich 261; 407 NW2d 367 (1987), this Court set forth procedures to govern the resolution of disputes at sentencing about the proper scoring of guidelines variables. Specifically, we adopted Standard 18-6.4(c) of the American Bar Association Standards for Criminal Justice. Walker, supra, pp 267-268. Paragraph c of this standard requires that the prosecutor prove a disputed variable by a preponderance of the evidence once the defendant has "effectively” challenged its accuracy. Id. It is consistent with our policy decision in Walker to adopt also paragraph b of the same standard in cases where the defendant is required to rebut pending or uncharged criminal allegations. Standard 18-6.4(b) provides:

[Where there is a need for further evidence] the sentencing court should conduct a hearing with respect to all material factual disputes arising out of any presentence reports or the evidentiary proffers of the parties. Although the sentencing process should not become a "minitrial,” occasions will arise when, in order to ensure that a sentence is not founded on material misinformation, the sentencing court should permit the parties to subpoena witnesses and to cross-examine persons who rendered [such] reports to the court and persons providing information contained in such reports. Hearsay and similar types of information inadmissible at trial may be received in the discretion of the court, but evidence offered by the parties should be subject to cross-examination.

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Cite This Page — Counsel Stack

Bluebook (online)
458 N.W.2d 880, 435 Mich. 443, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-ewing-mich-1990.