People of Michigan v. Hamin Lorenzo Dixon

Summary

The Michigan Supreme Court held that a 25-point score under OV 19 for possessing a cell phone in prison requires facts showing that the defendant’s conduct actually threatened prison security. Because the record showed only that Dixon was near a cell phone and that a charger was found in his cell, without evidence that he used the phone, planned to use it, or that it worked, the OV 19 score was improper. The Court reversed and remanded for resentencing.