STATE OF MICHIGAN

IN THE SUPREME COURT

Appeal from the Michigan Court of Appeals

(Swartzle, P.J., and Cavanaugh and Cameron, JJ.)

DAVONTAE SANFORD,

Plaintiff-Appellant,

v.

STATE OF MICHIGAN,

Defendant-Appellee.

MSC No. ________

COA No: 341879

Ct of Claims No: 17-000220

PLAINTIFF-APPELLANT – APPLICATION FOR LEAVE TO APPEAL

GOODMAN HURWITZ & JAMES, P.C.

By: William H. Goodman (P14173)

Julie H. Hurwitz (P34720)

1394 E. Jefferson Avenue

Detroit, Michigan 48207

(313) 567-6170

mail@goodmanhurwitz.com

Attorneys for Plaintiff-Appellant

B. Eric Restuccia (P49550)

Kathryn M. Dalzell (78648)

Office of Michigan Attorney General

Solicitor General Division

P.O. Box 30212

(517) 373-1124

restuccia@michigan.gov

dalzell@michigan,gov

Attorneys for Defendant-Appellee

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TABLE OF CONTENTS

ORDER/JUDGMENT APPEALED FROM ..................................................... iv

QUESTIONS FOR REVIEW ............................................................................. v

INDEX OF AUTHORITIES .............................................................................. vi

INTRODUCTION—WHY LEAVE SHOULD BE GRANTED ....................... 1

STATEMENT OF FACTS ................................................................................. 3

ARGUMENT ...................................................................................................... 5

I. THE COURT OF APPEALS ERRED IN DETERMINING

THAT COMPENSATION FOR WRONGFUL IMPRISONMENT

MAY ONLY BE AWARDED FOR TIME IMPRISONED IN A

STATE CORRECTIONAL FACILITY ............................................. 5

A. While the Statute Requires Incarceration in a “State

Correctional Facility” for Eligibility to Recover, there

is no Such Requirement in the Statute for Calculating

Compensation ................................................................................. 5

II. THE COURT OF APPEALS ERRED IN ADOPTING A NOVEL

AND ILL-CONCEIVED METHOD OF STATUTORY INTER-

PRETATION—THAT OF “ANCHORING” a PHRASE TO A

WORD THROUGHOUT THE STATUTE, EVEN THOUGH

PHRASE IS NOT USED. ................................................................... 8

III. THE COURT OF APPEALS ERRED WHEN IT INTERPRETED

THE WICA IN A WAY THAT UNDERMINES THE PURPOSE

AND INTENT OF THE LEGISLATURE BY GRAFTING A

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PHRASE INTO THE STATUTE THAT WAS NOT USED OR

INTENDED IN THAT PORTION OF THE WICA. ........................ 10

CONCLUSION AND REQUEST FOR RELIEF ............................................. 12

CERTIFICATE OF SERVICE ......................................................................... 14

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ORDER/JUDGMENT APPEALED FROM

Plaintiff-Appellant, Davontae Sanford, seeks leave to appeal from a April 9,

2019 decision of the Michigan Court of Appeals (Swartzle, P.J., and Cavanagh and

Cameron, JJ.), affirming the Court of Claims’ denial of Plaintiff’s request for WICA

compensation for 198 days of imprisonment in the Wayne County Juvenile

Detention Center. (Appx. 79a – 82a [COA Opinion]).

This application is being filed within 42 days of the Court of Appeals’ opinion,

as required by MCR 7.305(C)(2)(c).

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QUESTIONS FOR REVIEW

1. Did the Michigan Court of Appeals err in determining that merely because

eligibility for compensation under the Wrongful Imprisonment Compensation

Act (WICA) requires that a plaintiff be sentenced to a “state correctional

facility,” that the plaintiff’s compensation be limited only to time imprisoned

in such a facility and not to imprisonment in county or local facilities, even

though that limitation is not expressed in the statute?

Plaintiff-Appellant: YES

Defendant-Appellee: NO

2. Did the Court of Appeals err in its statutory interpretation of WICA, when it

used the concept of “anchoring” the eligibility requirement of having been

sentenced to a state correctional facility as a limitation in the calculation of

compensation, where the WICA says nothing about such a limitation for

purposes of calculating compensation?

Plaintiff-Appellant: YES

Defendant-Appellee: NO

3. Did the Court of Appeals err when it imposed a restriction on compensation,

only for time served in state correctional facilities, not articulated in the WICA

and inconsistent with the intent of the Legislature?

Plaintiff-Appellant: YES

Defendant-Appellee: NO

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INDEX OF AUTHORITIES

State Cases

Dept of Transportation v Tompkins, 481 Mich 184 749 (2008) ......................... 5

Empire Iron Mining Partnership v Orhan, 455 Mich 410 (1997) ...................... 9

In re MKK, 286 Mich App 546 (2009) ............................................................... 5

McCormick v Carrier, 487 Mich 180 (2010) ..................................................... 9

Miles v Fortney, 223 Mich 552 (1923) ............................................................... 1

People v McIntire, 461 Mich 147 (1999) ........................................................... 8

People v Rea, 500 Mich 422, 428 (2017) ........................................................ 7-8

People v Spann, 250 Mich App 527 (2002) ........................................................ 8

People v Taylor, 238 Mich App 259 (1999) ....................................................... 8

Tipton v State of Mississippi, 150 So 3d 82 (2014) .......................................... 12

State Statutes

MCL 7.215(B)(2) ................................................................................................ 1

MCL 600.5501 .................................................................................................. 11

MCL 600.5531 ................................................................................................. 11

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MCL 691.1751 et seq. ...................................................................................... 1,7

MCL 691.1752 .................................................................................................... 7

MCL 691.1753 .................................................................................................. 10

MCL 691.1755(1) ............................................................................................ 6,7

MCL 691.1755(2) ......................................................................................... 7, 11

Other Authority

Black’s Law Dictionary (6th ed. 1994) ......................................................... 8,12

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INTRODUCTION -WHY LEAVE SHOULD BE GRANTED

In 2017, the Michigan Legislature passed, and the Governor signed into law,

MCL 691.1751 et seq., the Wrongful Imprisonment Compensation Act (hereinafter

“WICA” or “the Act”), which became effective on March 29, 2017. The relatively

simple and solitary purpose of this law, as clearly delineated in its title, is to

compensate those persons who have been incarcerated—whether intentionally or

mistakenly—for crimes they did not commit. It is longstanding and universally

recognized jurisprudence in Michigan that “the first and controlling question for

determination is the legislative intent … (in the) declared purpose of the act as stated

in its title…” Miles v Fortney, 223 Mich 552, 557, (1923).

Yet, despite the clear intent of the Legislature to compensate individuals

unjustly stripped of their freedom, the Michigan Court of Appeals came to the jaw-

dropping conclusion that, even absent any statutory language so stating, a

wrongfully convicted person will be compensated only for the time he or she spends

wrongfully detained in a state prison, and not for time, arising from the very same

arrest and conviction, spent in a local jail, lockup, and/or juvenile detention cell. This

decision cries out for rectification.

Plaintiff-Appellant’s appeal from the Court of Claims decision presented

the Court of Appeals with an opportunity to address an issue arising under the new

statute—the WICA—that had not previously received appellate consideration or

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interpretation. As a matter of first impression, the Court of Appeals was required to

construe this provision of WICA by way of a published opinion. MCR 7.215(B)(2).

Inexplicably, however, the Court of Appeals designated its April 9, 2019 Opinion as

“unpublished.” In doing so, the appellate court not only disregarded the Michigan

Court Rules, but it downplayed the significance of this decision and its consequences

that go well beyond Plaintiff in this case and will have a broad and significant impact

on many others.

Moreover, this case presents: 1) an issue of first impression that will have far-

reaching consequences for all exonerated people who spent at least part of their

wrongfully imprisoned time as a pretrial detainees; and 2) is also brought against the

state. As such, it falls squarely within grounds that call for this Court to grant leave,

as set forth in MCR 2.305(B)(2):

(B) Grounds. The application must show that

* * *

(2) the issue has significant public interest and the case is

one by or against the state or one of its agencies or

subdivisions…

Therefore, Plaintiff-Appellant respectfully seeks leave to appeal that decision

to this Honorable Court, so that a newly enacted statute, intended to rectify injustice,

is correctly interpreted so as to properly serve that commendable purpose.

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STATEMENT OF FACTS

On September 18, 2017, Plaintiff-Appellant Davontae Sanford, at the age of

14, was taken into police custody. He remained wrongfully imprisoned,

continuously, for eight years and 264 days, until his release from prison on June 8,

2016, at age 23.

Due to a false and coerced “confession” and evidence that was fabricated by

Detroit Police Department (DPD) investigators, Mr. Sanford was arrested and

charged with four counts of first- degree premeditated murder, one count of assault

with intent to murder, one count of armed robbery, and one count of felony firearm.

DPD Officer Michael Russell testified falsely regarding Davontae’s so-called

confession at a pretrial suppression hearing and at a bench trial held on March 17

and 18, 2008.

Given the likelihood of conviction, in light of the DPD officers’ false

testimony and the fabricated confession, the 15-year-old was persuaded to plead

guilty and, consequently, was convicted of second-degree murder and felony

firearm. He was sentenced to 37 to 90 years of imprisonment in a state correctional

facility, with the 198 days that he served imprisoned in the Wayne County Juvenile

facility (from September 18, 2007 until April 4, 2008) credited toward his total state

sentence.

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After a thorough and exonerating investigation by the Michigan State Police,

Mr. Sanford’s conviction was vacated on June 6, 2016; and, on June 8, 2016, he was

released from prison.

On July 26, 2017, Sanford filed his Complaint in the Michigan Court of

Claims seeking compensation pursuant to WICA. On November 6, 2017, the

Michigan Attorney answered and immediately admitted Davontae Sanford’s

innocence. All that remained was a determination by the court as to the amount of

compensation to be awarded.

The parties each submitted briefs outlining their positions regarding

compensation. The primary disagreement was whether WICA provides

compensation for time—particularly time credited toward a plaintiff’s sentence—

imprisoned in facilities other than in a “state correctional facility.” In this case, that

time amounts to 198 days, which would, if allowed, total $27,124.02 owed to

Plaintiff.

On December 4, 2017, the Court of Claims held a hearing, where the issue

was addressed. (Appx. **, 12/4/17 Hearing Transcript, pp.12-22). There, the court

ruled that WICA provides for compensation for time spent behind bars, but only in

state correctional facilities. On December 26, 2017, the parties stipulated to an order

of judgment that preserved that issue for appeal to the Court of Appeals, which

followed. (Appx. 60a – 61a [Stip. Order of Judgment, 12/21/17]).

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On April 9, 2019, the Court of Appeals affirmed the Court of Claims. In a

four-page opinion, the Court, virtually without citation to case law or authority, held

that “the Court of Claims did not err by rejecting plaintiff's claim for compensation

for pretrial detention in a local facility.” (Appx. 81a [COA Order, p.3]). It is this

from this conclusion, as well as from its underlying flawed analysis, that Plaintiff

now seeks leave to appeal.

ARGUMENT

I. THE COURT OF APPEALS ERRED IN DETERMINING THAT

COMPENSATION FOR WRONGFUL IMPRISONMENT MAY

ONLY BE AWARDED FOR TIME IMPRISONED IN A STATE

CORRECTIONAL FACILITY.

Questions of statutory construction are reviewed de novo. Dept of

Transportation v Tompkins, 481 Mich 184, 190, 749 NW2d 716 (2008).

Statutory language should be construed reasonably, keeping in mind

the purpose of the act. The purpose of judicial statutory construction is

to ascertain and give effect to the intent of the Legislature. In

determining the Legislature's intent, we must first look to the language

of the statute itself.

In re MKK, 286 Mich App 546, 556–57, 781 NW2d 132, 139 (2009) (citations

omitted).

A. While the Statute Requires Incarceration in a “State

Correctional Facility” for Eligibility to Recover, there is no Such

Requirement in the Statute for Calculating Compensation.

In order to understand the flawed logic in the opinion below, it is necessary to

understand the basic outline of the WICA. For purposes of this case, liability under

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this statute requires a two-part analysis: first, eligibility for compensation; and

second, calculation of the amount of compensation owed.

Section 5(1) of WICA sets forth the criteria that must be met to provide

judgment in a plaintiff’s favor. Specifically, the plaintiff must prove, by clear and

convincing evidence, that:

(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… [and]

(c) New evidence demonstrates that the plaintiff did not

perpetrate the crime and was not an accomplice or an

accessory to the acts that were the basis of the conviction…

MCL § 691.1755(1). (Emphasis added).1

The Act states, in pertinent part, “if a court finds that a plaintiff was

wrongfully convicted and imprisoned, the court shall award . . [f]ifty thousand

dollars for each year from the date the plaintiff was imprisoned until the date the

plaintiff was released from prison …” MCL § 691.1755 (2)(a). (Emphasis added).

The central question presented here is one of statutory construction: whether,

in calculating a plaintiff’s damages, the word “imprisoned,” as used in the

1 The parties below stipulated, and the Court of Claims agreed, that Mr. Sanford was

entitled to judgment in his favor. Thus, none of these elements were ever in dispute.

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compensation portion of the WICA, necessarily implies imprisonment in a “state

correctional facility” or whether it may include other venues of imprisonment, such

as jails, lockups, and juvenile detention facilities?

The court below found that “imprisonment in a state correctional facility” is a

threshold criterion for establishing liability, MCL §691.1755(1)(a) and that criterion

somehow “anchors” the requirement of a “state correctional facility” to the

calculation of the amount to be awarded for wrongful imprisonment, even though

the phrase “state correctional facility” is not used in the portion of the statute that

discusses the calculation of compensation—MCL § 691.1755(2).

Notably, the terms “imprisoned,” “imprisonment,” and “imprisoned in a state

correctional facility” are used repeatedly in the WICA. MCL § 691.1751, et seq. It

is significant that none of those words or phrases are to be found in the “Definitions”

section of the statute, MCL § 691.1752. This Court has held that “(w)hen a word or

phrase is not defined by the statute in question, it is appropriate to consult dictionary

definitions to determine the plain and ordinary meaning of the word or phrase.”

People v Rea, 500 Mich 422, 428 (2017).

Had the Black’s Law Dictionary definition of “imprisonment” been sought,

as Rea, supra, teaches, here is what it would have disclosed: “to put in a prison; to

put in a place of confinement. To confine a person or restrain his liberty in any way.”

Black’s Law Dictionary (6th ed. 1994) This definition is supported by Michigan case

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law as well. See People v Taylor, 238 Mich App 259, 262 (1999) (“defendant was

‘lawfully imprisoned in a jail’ when he escaped”) (emphasis added); People v Spann,

250 Mich App 527, 531 (2002) (“The common meaning of “imprisonment” supports

a conclusion that the phrase “term of imprisonment” includes a sentence of jail

incarceration.”)

II. THE COURT OF APPEALS ERRED IN ADOPTING A NOVEL

AND ILL-CONCEIVED METHOD OF STATUTORY

INTERPRETATION— THAT OF “ANCHORIING” A

PHRASE TO A WORD THROUGHOUT THE STATUTE,

EVEN THOUGH THAT PHRASE IS NOT USED.

Rather than proceed with the teaching of Rea (as well as published case law,

such as Spann) the Court of Appeals chose to create a wholly novel strategy of

statutory interpretation—that of the “anchoring” a phrase to another word

throughout the statute, regardless of whether that phrase is expressed or not (Appx.

81a [COA Opinion, p.3]). This, of course, enables a serious deviation from the

actual text of the statute and, as such, is highly problematic. Further, it flies in the

face of the fundamental principles of statutory interpretation long set forth by this

Court.

When a legislature has unambiguously conveyed its intent in a statute,

the statute speaks for itself and there is no need for judicial

construction; the proper role of a court is simply to apply the terms of

the statute to the circumstances in a particular case.

People v McIntire, 461 Mich 147, 153 (1999).

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This concept of “anchoring” is contrary to accepted jurisprudence relating to

statutory construction, in that it inserts words and meaning into a portion of the

statute wherein a court is required to assume meaning and context to the omission

of that very word or phrase. “We avoid inserting words in statutes unless necessary

to give intelligible meaning or to prevent absurdity.” Empire Iron Mining

Partnership v Orhan, 455 Mich 410, 424 (1997). Since intelligible meaning is

available to the word “imprisoned,” standing alone, the insertion of the phrase “in a

state correctional facility” is both unnecessary and also fails to eliminate any

absurdity. Moreover, it undermines the underlying purpose of the WICA—to fairly

and fully compensate those unjustly imprisoned.

If the statute itself is clear, it is presumed that the Legislature intended the

meaning so expressed in the statute. McCormick v Carrier, 487 Mich 180, 191, 795

NW2d 517, 524 (2010). There is no lack of clarity in the WICA. Nor is there any

reason to “anchor” an unexpressed phrase to a word, so as to deny recovery to

qualifying plaintiffs for all time spent wrongfully imprisoned, since compensation

for the grave injustice of wrongful imprisonment is the clear purpose of WICA.

Rather, the fact that the phrase “in a state correctional facility” was deleted—i.e.

deliberately not used in the compensation section of the WICA—must be given

meaning and purpose. See People v Williams, 491 Mich 164, 177 (2012).

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III. THE COURT OF APPEALS ERRED WHEN IT

INTERPRETED THE WICA IN A WAY THAT UNDERMINES

THE PURPOSE AND INTENT OF THE LEGISLATURE

Since the Legislature intended to provide compensation for wrongful

imprisonment to people who were sentenced to a term of imprisonment in a state

correctional facility, and it did not limit compensation to only that time spent in a

state facility, the Court of Appeals interpretation is inconsistent, both with the

common usage of the language in the compensation provision of the Act, as well as

with the very purpose of the WICA.

The Court of Claims’ decision puts greater emphasis on the term “state

correctional facility” than is reasonably construed in the statute itself. “State

correctional facilities” are discussed at various points throughout the Act; however,

not with respect to the award of compensation. Of particular note is the language in

Section 3 of the Act, which states,

An 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 may bring an action for compensation against

this state in the court of claims as allowed by the act.

MCL § 691.1753. This section merely sets forth the basic standard for triggering

the Act—or the threshold for eligibility. In other words, the Act does not apply

where an individual was not convicted under Michigan law, nor does it apply where

an individual was convicted but served only probation or only time in a county

facility. Significantly, nowhere in the Act does the Legislature limit compensation

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to only the days that a plaintiff was imprisoned in a state facility, nor does it say that

compensation would be paid for each year beginning only on the date that the

plaintiff was convicted, sentenced, or any event other than “the date plaintiff was

imprisoned.” MCL § 691.1755(2)(a).

It is noteworthy that elsewhere in Michigan statutory language, the

Legislature has defined “prison” broadly, to wit: “‘Prison’ means a facility that

incarcerates or detains juveniles or adults accused of, convicted of, sentenced for or

adjudicated delinquent for, violations of state or local law.” MCL § 600.5531.2

Thus, the Legislature has evidenced the understanding that the word prison

encompasses more than simply a state correctional facility; similarly, the plain

language of the WICA indicates the Legislature’s ability to use the phrase “in a state

correctional facility” in conjunction with the word ”imprisoned” as well as the ability

and intent to use the phrase and the word separately. Thus, the clear (and

unanchored) legislative intent of the WICA was to award victims of wrongful

imprisonment compensation for the complete duration of their wrongful

imprisonment, including wrongful imprisonment in jail while awaiting trial and

sentencing.

2 This is the “Definitional” section of MCL § 600.5501 et seq., otherwise known

as the Michigan Prisoner Litigation Reform Act.

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It should be noted that other courts of other states have rejected the

interpretation advanced by the Michigan Court of Appeals in this case, finding such

interpretation to be inconsistent with the purpose of these compensation statutes. For

example, in Tipton v State of Mississippi, 150 So 3d 82 (2014), the Supreme Court

of Mississippi clearly stated that

… the interpretation of what it means to be subjected to a period of

imprisonment, and whether someone under house arrest can be said to

have been imprisoned during that period …. The purpose of the

compensation statutes is to compensate innocent persons who … were

wrongly convicted of felonies and subsequently imprisoned …. The

definition of “imprisonment” is not limited to addressing only

imprisonment in “brick and mortar” prisons. Webster’s Dictionary

defines “imprison” as “to confine in or as if in prison.” …. Black’s Law

Dictionary defines “imprisonment” as “[t]he act of confining a person,

esp. in a prison,” or “[t]he state of being confined; a period of

confinement.” Black’s Law Dictionary …. Accordingly, imprisonment

may occur in an actual prison, but it also can include a state of

confinement, which can occur anywhere and vary widely in degree.

Id. at 84-85

CONCLUSION AND REQUEST FOR RELIEF

In affirming the Court of Claims, the Michigan Court of Appeals insisted that

the phrase “in a state correctional facility” be grafted onto the word “imprisoned,”

although the statute is both comprehensible and consistent with its statutory purpose,

without such manipulation. To have given the statute its logical and un-contorted

meaning would have allowed Plaintiff to be compensated. To adhere to the position

of the Court of Appeals would deprive the Plaintiff of 198 days of compensation to

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which he is entitled, pursuant to the WICA.

Equally as urgent: if the opinion below is followed, or if indeed the reasoning

of the Court of Appeals below is followed, many persons who were wrongfully

arrested, charged, convicted, and imprisoned will be deprived of the full right to

complete compensation and some measure of belated justice.3 As such, this

application for leave raises a definitive issue of public policy, making it of

“significant public interest.” MCR 7.305(B)(2).

WHEREFORE, based on the foregoing, Plaintiff Hart respectfully requests

that this Honorable Court grant his Application for Leave to Appeal.

Respectfully submitted,

Goodman Hurwitz & James, P.C.

/s/ William H. Goodman

William H. Goodman (P14173)

1394 E. Jefferson Avenue

Detroit, Michigan 48207

Tel : (313) 567-6170

bgoodman@goodmanhurwitz.com

Dated: May 21, 2019

3 It also must be noted that prohibiting compensation for a wrongfully convicted

plaintiff’s presentence time of imprisonment, unfairly discriminates against those

who were indigent at the time of their arrest and could not afford to post bond. This

situation, which disproportionately affects African American and immigrant

communities, increases the pre-conviction time imprisoned and decreases time spent

in state custody, where the indigent person’s pretrial imprisonment is credited

toward his or her sentence without appropriate compensation. (Appx. 22a, [CoC

Hearing Trx, p.19]; Appx. 72a – 74a [Pls Brief on Appeal, p.6-8])

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CERTIFICATE OF SERVICE

I certify that on May 21, 2019, I served a copy of Plaintiff- Appellant -

Application for Leave to Appeal via electronic mail upon the following:

B. Eric Restuccia restuccia@michigan.gov

Kathryn M. Dalzell dalzell@michigan.gov

Office of Michigan Attorney General

Solicitor General Division 525 W.Ottawa

P.O. Box 30212 Lansing, MI 48933

Attorneys for Defendant-Appellee

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