People v. Wiley
Cases that cite this one
34 later published cases cite this decision. The 25 that cite it most often are listed here.
- People of Michigan v. Richard James Guichelaar (Mich. Ct. App. 2023)
- People v. McKay (Mich. 2005)
- People of Michigan v. Robert Cecil Burr II (Mich. Ct. App. 2019)
- People of Michigan v. Brandon Allen Smith (Mich. Ct. App. 2017)
- People of Michigan v. Brandon Allen Smith (Mich. Ct. App. 2017)
- People of Michigan v. Micah Henry Rickerd (Mich. Ct. App. 2024)
- People v. Malinowski (Mich. Ct. App. 2013)
- People v. Price (Mich. 2006)
- People of Michigan v. Jake Darnell Grady-Wilkins (Mich. Ct. App. 2025)
- People of Michigan v. Craig Ivan Hill (Mich. Ct. App. 2022)
- People of Michigan v. Robert Earl Kennedy (Mich. Ct. App. 2020)
- People of Michigan v. Dominique Demetrius Miller (Mich. Ct. App. 2019)
- People of Michigan v. Dominique Demetrius Miller (Mich. Ct. App. 2018)
- People of Michigan v. James Francis Rapp (Mich. Ct. App. 2017)
- People of Michigan v. Andrew William Bock (Mich. Ct. App. 2015)
- People of Michigan v. Jonathan Aponte (Mich. Ct. App. 2014)
- People of Michigan v. Christopher Lee Johnson (Mich. Ct. App. 2023)
- People of Michigan v. Jacques Shanta Williams (Mich. Ct. App. 2018)
- People of Michigan v. Jacques Shanta Williams (Mich. Ct. App. 2018)
- People of Michigan v. Gary Gilmore (Mich. Ct. App. 2018)
- People v. Farris (Mich. 2018)
- People of Michigan v. Charles Ray Jones (Mich. Ct. App. 2017)
- People of Michigan v. Charles Ray Jones (Mich. Ct. App. 2017)
- People of Michigan v. James Daniel Seadorf (Mich. Ct. App. 2017)
- People of Michigan v. James Daniel Seadorf (Mich. Ct. App. 2017)
This list shows which later cases cite this one. It does not say how they treated it, and no review of that has been done. Not a substitute for Shepard’s or KeyCite — verify before relying.
Opinion
MEMORANDUM OPINION
We hold that a sentence that exceeds the sentencing guidelines satisfies the requirements of MCL 769.34(3) when the record confirms that the sentence was imposed as part of a valid plea agreement. Under such circumstances, the statute does not require the specific articulation of additional “substantial and compelling” reasons by the sentencing court. MCL 769.34(3); People v Babcock, 469 Mich 247, 256-258; 666 NW2d 231 (2003).
Furthermore, a defendant waives appellate review of a sentence that exceeds the guidelines by understandingly and voluntarily entering into a plea agreement to accept that specific sentence. 1 MCR 6.302. In that respect, this case is similar to People v Cobbs, 443 Mich 276, 285; 505 NW2d 208 (1993), in which this Court stated that a defendant who pleads guilty with knowledge of the sentence will not be entitled to appellate relief on the basis that the sentence is disproportionate. See also People v Carter, 462 Mich 206, 215-216; 612 NW2d 144 (2000).
*155 We therefore affirm the judgment of the trial court. In all other respects, defendant’s application for leave to appeal is denied, because we are not persuaded that this Court should review the other questions presented.
It is fully understandable under the circumstances of a plea agreement why a defendant would waive appellate review of such a sentence, because it is implicit in every plea agreement that the defendant has derived some benefit from the agreement, otherwise it would not have been entered into. However, there is no obligation upon the sentencing court to identify the reasons underlying the defendant’s acceptance of the plea agreement or to inventory the specific benefits that the defendant might have derived. Nevertheless, the court should complete the Sentencing Information Report and determine the appropriate guideline range, so that it is clear that the agreed-upon sentence constitutes a departure.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.