People v. Cathey

I respectfully disagree with the majority’s reliance on People v Woods, 204 Mich App 472; 517 NW2d 239 (1994), and I further disagree with the conclusion that pregnancy constitutes a “bodily injury” within the meaning of Offense Variable (OV) 3, MCL 777.33.

In Woods, supra, this Court was interpreting the judicial sentencing guidelines promulgated by the *518Michigan Supreme Court, not a statutory provision enacted by the Legislature such as MCL 777.33. Because a legislative enactment was not involved, the Woods panel did not apply the governing rules for statutory construction. In Pohutski v City…