Sentencing; People v Lockridge; Reasonableness & proportionality; Appealability; MCL 769.34(10); People v Kimble; Departure sentencing; People v Steanhouse; People v Milbourn; Consideration of a defendant’s criminal history; People v Hansford; People v Adams

The court held that the trial court appropriately imposed a reasonable and proportionate sentence. Defendant pled guilty to fourth-degree fleeing and eluding a police officer and sentenced to 14 to 24 months. The trial court denied his motion to correct an invalid sentence, which was based on his assertion that it improperly sentenced him without providing substantial and compelling reasons when the statute provided for an intermediate sentence in jail. On appeal, the court rejected his argument that the trial court abused its discretion by sentencing him to a minimum sentence of 14 months in prison, rather than a term of 12 months in jail. “The trial court considered all of the evidence and based its sentence, as required, on the seriousness of the offense and the offender. The trial court’s imposition of a prison sentence, rather than a jail term, served the purpose of disciplining defendant for the seriousness of his offense and accounted for his repeated criminal activity and failure to rehabilitate.” The imposition of a prison sentence, rather than a jail sentence, “was ‘proportionate to the seriousness of the circumstances surrounding the offense and the offender.’” Affirmed.