Sanford v. State

• Decision Date: 23 July 2020
• Docket Number: No. 159636,159636
• Citation: 954 N.W.2d 82,506 Mich. 10
• Parties: Davontae SANFORD, Plaintiff-Appellant, v. STATE of Michigan, Defendant-Appellee.
• Court: Michigan Supreme Court

506 Mich. 10

954 N.W.2d 82

Davontae SANFORD, Plaintiff-Appellant,

v.STATE of Michigan, Defendant-Appellee.

No. 159636

Supreme Court of Michigan.

Argued on application for leave to appeal May 6, 2020

Decided July 23, 2020

Zahra, J.

The issue presented in this case is one of first impression arising from the Wrongful Imprisonment Compensation Act (WICA), MCL 691.1751 et seq. , a relatively new law that became effective March 29, 2017. The WICA waives sovereign immunity and creates a cause of action for certain people wrongfully imprisoned by the state of Michigan. The question before this Court is whether the WICA authorizes compensation for the time plaintiff spent in detention before he was wrongfully convicted of a crime. We conclude that it does not, because plaintiff's preconviction detention was not "wrongful" for purposes of the WICA. We therefore affirm the result reached by the Court of Appeals.

I. BASIC FACTS AND PROCEEDINGS

Plaintiff, who was 15 years old at the time, pleaded guilty to four counts of second-degree murder and carrying a firearm during the commission of a felony in connection with a highly publicized and notorious quadruple homicide in Detroit on September 17, 2007. On April 4, 2008, he was sentenced by the circuit court to concurrent terms of 37 to 90 years in prison for the murder convictions, plus a consecutive 2-year term for the felony-firearm conviction, with credit for the 198 days he spent in the Wayne County Juvenile Detention Facility.

In May 2015, the Michigan State Police reopened the investigation into the murders after a self-proclaimed hit man and convicted murderer confessed to them. This newly discovered evidence indicated that plaintiff had not committed the crimes to which he had pleaded guilty and of which he was convicted. As a result of this investigation and with the stipulation of the prosecutor, the circuit court vacated plaintiff's convictions and sentences on June 6, 2016, and plaintiff was released from the Michigan Department of Corrections (MDOC) on June 8, 2016. From April 8, 2008, to June 8, 2016, plaintiff spent 8 years and 61 days in the custody of the MDOC.

On July 27, 2017, plaintiff filed a complaint in the Court of Claims seeking compensation from defendant under the WICA. Defendant admitted that plaintiff was entitled to $408,356.16 in compensation for the 8 years and 61 days he spent in a state correctional facility pursuant to the WICA's damages formula set forth in MCL 691.1755(2)(a). But the parties disputed whether plaintiff was entitled to $27,124.02 in compensation for the 198 days he spent in local detention. The Court of Claims held that the time plaintiff spent in local detention is not compensable under the WICA, and it awarded plaintiff $408,356.16.

Plaintiff appealed as of right, and the Court of Appeals affirmed the Court of Claims in an unpublished per curiam opinion. Plaintiff sought leave to appeal in this Court, and in lieu of granting leave, we ordered oral argument on the application, directing the parties to file supplemental briefs addressing "whether the plaintiff is entitled to compensation under the Wrongful Imprisonment Compensation Act, MCL 691.1751 et seq. , for time spent in a juvenile facility before he was convicted of a crime."¹

II. STANDARD OF REVIEW

This Court reviews de novo questions of statutory interpretation.² The role of this Court in interpreting statutory language is to "ascertain the legislative intent that may reasonably be inferred from the words in a statute."³ "The focus of our analysis must be the statute's express language, which offers the most reliable evidence of the Legislature's intent."⁴ When the statutory language is clear and unambiguous, judicial construction is limited to enforcement of the statute as written.⁵

III. ANALYSIS

Before March 29, 2017, people who were wrongfully imprisoned by the state of Michigan had no recourse against it for compensation. "From the time of Michigan's statehood, this Court's jurisprudence has recognized that the state, as sovereign, is immune from suit unless it consents ...."⁶ The WICA is an express waiver of the state's sovereign immunity. Specifically, MCL 691.1753 permits "[a]n individual convicted under the law of this state and subsequently imprisoned in a state correctional facility for 1 or more crimes that he or she did not commit" to "bring an action for compensation against this state in the court of claims as allowed by this act." To do so, the plaintiff must show that he or she "served at least part of the sentence" for those crimes.⁷ A "state correctional facility" is defined in the WICA as "a correctional facility maintained and operated by the department of corrections."⁸

The WICA's section governing compensation and burden of proof, MCL 691.1755, states in pertinent part:

(1) In an action under this act, the plaintiff is entitled to judgment in the plaintiff's favor if the plaintiff proves all of the following by clear and convincing evidence:

(a) The plaintiff was convicted of 1 or more crimes under the law of this state, was sentenced to a term of imprisonment in a state correctional facility for the crime or crimes, and served at least part of the sentence.

(b) The plaintiff's judgment of conviction was reversed or vacated and either the charges were dismissed or the plaintiff was determined on retrial to be not guilty. However, the plaintiff is not entitled to compensation under this act if the plaintiff was convicted of another criminal offense arising from the same transaction and either that offense was not dismissed or the plaintiff was convicted of that offense on retrial.

(c) New evidence demonstrates that the plaintiff did not perpetrate the crime and was not an accomplice or accessory to the acts that were the basis of the conviction, results in the reversal or vacation of the charges in the judgment of conviction or a gubernatorial pardon, and results in either dismissal of all of the charges or a finding of not guilty on all of the charges on retrial.

(2) Subject to subsections (4) and (5),^[9] if a court finds that a plaintiff was wrongfully convicted and imprisoned, the court shall award compensation as follows:

(a) Fifty thousand dollars for each year from the date the plaintiff was imprisoned until the date the plaintiff was released from prison, regardless of whether the plaintiff was released from imprisonment on parole or because the maximum sentence was served. For incarceration of less than a year in prison, this amount is prorated to 1/365 of $50,000.00 for every day the plaintiff was incarcerated in prison.

In this case, plaintiff's entitlement to compensation is not in dispute, as defendant concedes that plaintiff has established the requirements set forth in MCL 691.1755(1). The narrow question presented relates to the scope of the compensation available under the WICA—specifically, whether under MCL 691.1755(2) plaintiff is entitled to compensation for the time he spent in detention before his conviction.

In analyzing these provisions, we must keep in mind that the WICA does not broadly direct courts to make those who were wrongfully imprisoned whole. Indeed, no amount of compensation could sufficiently remedy the deprivation of liberty suffered by those entitled to compensation under the WICA. But, as a matter of public policy, the Legislature has waived its sovereign immunity to provide a defined class of wrongfully imprisoned people a path to limited compensation. It is the exclusive province of the Legislature to define when and to what extent the state of Michigan relinquishes its sovereign immunity.

Plaintiff asserts that the WICA is properly considered a remedial statute, which calls for a liberal construction from this Court.¹⁰ Defendant counters that the WICA constitutes a waiver of sovereign immunity, which must be strictly construed.¹¹ But, in giving meaning to the WICA, we decline to rely on the interpretive rules advocated for by either party. A " ‘rule of liberal construction will not override other rules where its application would defeat the intention of the legislature or the evident meaning of an act.’ "¹² And "[t]his Court has more recently tended to restrain calls for liberal or strict construction, opting instead for a reasonable construction of all legal texts."¹³ Consequently, we find no need to place a thumb on the scale in favor of one party over the other, and this Court will take a reasonable-construction approach in giving meaning to the unambiguous language of the WICA.

From this perspective, we turn to the issue of statutory interpretation. We conclude that the WICA provides sufficient textual clues to support the Court of Appeals’ holding that plaintiff may not be compensated for the time he spent in detention before his conviction, although we reach this conclusion for different reasons.

Plaintiff concedes that, in order to qualify for any compensation under the WICA, a plaintiff must serve some time in a state correctional facility, a requirement established by MCL 691.1753, MCL 691.1754(1), and MCL 691.1755(1)(a). Plaintiff and defendant primarily disagree about the meaning of the term "imprisoned" as used in the compensation provision of MCL 691.1755(2)(a). Plaintiff argues that dictionary definitions of the terms "imprison" and "imprisonment" are broad enough to encompass confinement in a local facility, meaning the entirety of his detention is compensable. In contrast, defendant contends that "imprisoned" for purposes of this subsection refers solely to confinement in a state correctional facility. The Court of Appeals agreed with defendant's interpretation, concluding that the "threshold requirement" of "imprisonment in a state correctional facility" imposed after conviction "anchors" the amount of compensation referred to in MCL 691.1755(2)(a).¹⁴ But this Court need not define the exact contours of the term "imprisoned" as used in MCL 691.1755(2)(a) in order to resolve this case....