People v. Smith

The issue presented in this case is whether offense variable (OV) 19, MCL 777.49, maybe scored for aggravating conduct that occurred after the sentencing offense was completed. In People v McGraw, this Court held that “[o]ffense variables must be scored giving consideration to the sentencing offense alone, unless otherwise provided in the particular variable.”1 Here, we hold that because the circumstances described in OV 19 expressly include events occurring after the completion of the sentencing offense, scoring OV 19 necessarily is not limited to consideration of the sentencing offense.…