People v. McGraw

This case involves further analysis of the issue presented in People v Sargent.1 There we held that offense variable (OV) 9 in the sentencing guidelines1 2 *122cannot be scored using uncharged acts that did not occur during the same criminal transaction as the sentencing offense. Today we decide whether the offense variables should be scored solely on the basis of conduct occurring during the sentencing offense3 or also using conduct occurring afterward.

We hold that a defendant’s conduct after an offense is completed does not relate back to the sentencing offense for purposes of scoring offense…