People v. Laidler

The issue in this case is whether the death of a coperpetrator of a crime may be scored under offense variable (OV) 3, MCL 777.33, which concerns “physical injury to a victim.” We conclude that a coperpetrator is properly considered a “victim” for purposes of OV 3 when he or she is harmed by the criminal actions of the charged party, in this case, defendant. Because we conclude that the coperpetrator’s death constituted such a harm, we reverse in part the judgment of the Court of Appeals and reinstate defendant’s sentence. The trial court properly assessed 100 points for OV 3 because the…