Mich. Comp. Laws » Michigan Compiled Laws / Chapter 777 / Act 175 of 1927
Michigan Compiled Laws

Mich. Comp. Laws § 777.52 (2026)

Prior low severity felony convictions.

✓ current as of July 2026
Find cases: SyfertCases citing this section MI-LEGlegislature.mi.gov JustiaChapter on Justia CornellLII Search CasesGoogle Scholar

THE CODE OF CRIMINAL PROCEDURE


Act 175 of 1927


777.52 Prior low severity felony convictions.

Sec. 52.

    (1) Prior record variable 2 is prior low severity felony convictions. Score prior record variable 2 by determining which of the following apply and by assigning the number of points attributable to the one that has the highest number of points:

    

    (a) The offender has 4 or more prior low severity felony convictions

    30 points

    (b) The offender has 3 prior low severity felony convictions

    20 points

    (c) The offender has 2 prior low severity felony convictions

    10 points

    (d) The offender has 1 prior low severity felony conviction

    5 points

    (e) The offender has no prior low severity felony convictions

    0 points

    (2) As used in this section, "prior low severity felony conviction" means a conviction for any of the following, if the conviction was entered before the sentencing offense was committed:

    (a) A crime listed in offense class E, F, G, or H.

    (b) A felony under a law of the United States or another state that corresponds to a crime listed in offense class E, F, G, or H.

    (c) A felony that is not listed in offense class M2, A, B, C, D, E, F, G, or H and that is punishable by a maximum term of imprisonment of less than 10 years.

    (d) A felony under a law of the United States or another state that does not correspond to a crime listed in offense class M2, A, B, C, D, E, F, G, or H and that is punishable by a maximum term of imprisonment of less than 10 years.

    

History: Add. 1998, Act 317, Eff. Dec. 15, 1998 ;-- Am. 2006, Act 655, Imd. Eff. Jan. 9, 2007

Notes of Decisions
Cited in 87 cases (27 in the last 5 years), 2007–2026 · leading case: People v. Harper, 739 N.W.2d 523 (Mich. 2007).
Sort: Relevance Newest Treatment
People v. Harper, 739 N.W.2d 523 (Mich. 2007). · cites it 4× “51; MCL 777.52; MCL 777.55. [7] MCL 777.46(1)(c).”
People v. Crews, 829 N.W.2d 898 (Mich. Ct. App. 2013). · cites it 5× “51, PRV 2, MCL 777.52, and PRV 5, MCL 777.55. Specifically, defendant argued that PRV 1 was improperly scored because his convictions for burglaries in Ohio did not correspond to any Michigan felonies and, accordingly, could not be used as prior high-severity offenses under PRV…”
People v. Young, 740 N.W.2d 347 (Mich. Ct. App. 2007). · cites it 2× “51, MCL 777.52, MCL 777.53, MCL 777.54, and MCL 777.”
People v. Allen, 884 N.W.2d 548 (Mich. 2016). · cites it 2× “51, a “high severity felony conviction” is defined in part as a conviction for a “crime listed in class M2, A, B, C, or D”; when scoring PRV 2, MCL 777.52, a “low severity felony conviction” is defined in part as a conviction for a “crime listed in class E, F, G, or H[.”
People v. Marshall, 830 N.W.2d 414 (Mich. Ct. App. 2012). “Further, the conviction information section of the sentencing information report listed “4th or subsequent” in the space for habitual-offender information and listed a score of 30 points for prior record variable 2, indicating that defendant has four or more prior, low-severity…”
People v. Young, 740 N.W.2d 347 (Mich. Ct. App. 2007). · cites it 2× “51, MCL 777.52, MCL 777.53, MCL 777.54, and MCL 777.”
People v. Butler, 892 N.W.2d 6 (Mich. Ct. App. 2016). “MCL 777.52. MCL 777.53. MCL 777.54. MCL 777.”
People v. Wright, 767 N.W.2d 447 (Mich. 2009). · cites it 2× “Because assault with intent to do great bodily harm is a class D offense, and an attempt to commit a class A, B, C, or D offense is a class E offense, the defendant's prior conviction for attempted assault with intent to do great bodily harm was a class E offense. MCL…”
People v. Meeks, 293 Mich. App. 115 (Mich. Ct. App. 2011). · cites it 3× “MCL 777.52(1)(d) prescribes the assessment of five points when the defendant has one prior low-severity felony conviction.”
People of Michigan v. Moses Richard Emmanuel (Mich. Ct. App. 2026). · cites it 7× “PRV 2 is contained in MCL 777.52, which provides as follows: (1) Prior record variable 2 is prior low severity felony convictions.”
People of Michigan v. Antoine Earico Bowman (Mich. Ct. App. 2021). · cites it 5× “MCL 777.52(1). An assessment of 30 points is required if the offender has four or more prior low severity felony convictions.”
People of Michigan v. Isaiah Buckner (Mich. Ct. App. 2021). · cites it 5× “52(2), a “prior low severity felony conviction” means a conviction entered before the sentencing offense was committed that falls within the categories provided in MCL 777.”
Show all 87 citing cases →
— Mich. Comp. Laws § 777.52(1) — 11 cases
People of Michigan v. Alvin Tryon Harris (Mich. Ct. App. 2017).
People of Michigan v. Alvin Tryon Harris (Mich. Ct. App. 2017).
People of Michigan v. Michael Allen Taylor (Mich. Ct. App. 2019).
People of Michigan v. Antoine Earico Bowman (Mich. Ct. App. 2021). “MCL 777.52(1). An assessment of 30 points is required if the offender has four or more prior low severity felony convictions.”
People of Michigan v. Isaiah Buckner (Mich. Ct. App. 2021). “52(2), a “prior low severity felony conviction” means a conviction entered before the sentencing offense was committed that falls within the categories provided in MCL 777.”
— Mich. Comp. Laws § 777.52(1)(a) — 24 cases
People of Michigan v. Steve Wynale Griffin (Mich. Ct. App. 2018).
People of Michigan v. Steve Wynale Griffin (Mich. Ct. App. 2018).
People of Michigan v. Ronald Johnson (Mich. Ct. App. 2014).
People of Michigan v. Paul Peter Gross (Mich. Ct. App. 2015).
People of Michigan v. Steven Smith (Mich. Ct. App. 2018).
— Mich. Comp. Laws § 777.52(1)(b) — 14 cases
People v. Harper, 739 N.W.2d 523 (Mich. 2007). “51; MCL 777.52; MCL 777.55. [7] MCL 777.46(1)(c).”
People of Michigan v. Marcus Henry Hearn (Mich. Ct. App. 2022).
People of Michigan v. Frederick Harvey Grumbley (Mich. Ct. App. 2017).
People of Michigan v. Alvin Tryon Harris (Mich. Ct. App. 2017).
People of Michigan v. Alvin Tryon Harris (Mich. Ct. App. 2017).
— Mich. Comp. Laws § 777.52(1)(c) — 5 cases
People of Michigan v. Darryl Keith Stewart (Mich. Ct. App. 2019).
People of Michigan v. Deandre Harris (Mich. Ct. App. 2020).
People of Michigan v. Antoine Earico Bowman (Mich. Ct. App. 2021). “MCL 777.52(1). An assessment of 30 points is required if the offender has four or more prior low severity felony convictions.”
People of Michigan v. Isaiah Buckner (Mich. Ct. App. 2021). “52(2), a “prior low severity felony conviction” means a conviction entered before the sentencing offense was committed that falls within the categories provided in MCL 777.”
People of Michigan v. Jamal Devonta Bennett (Mich. Ct. App. 2024).
— Mich. Comp. Laws § 777.52(1)(d) — 8 cases
People v. Meeks, 293 Mich. App. 115 (Mich. Ct. App. 2011). “MCL 777.52(1)(d) prescribes the assessment of five points when the defendant has one prior low-severity felony conviction.”
People of Michigan v. Leon Cavanaugh Jr (Mich. Ct. App. 2025).
People of Michigan v. David Wesley Mercer (Mich. Ct. App. 2018).
People of Michigan v. David Wesley Mercer (Mich. Ct. App. 2018).
People of Michigan v. Deandre Harris (Mich. Ct. App. 2020).
— Mich. Comp. Laws § 777.52(1)(e) — 2 cases
People v. Young, 740 N.W.2d 347 (Mich. Ct. App. 2007). “51, MCL 777.52, MCL 777.53, MCL 777.54, and MCL 777.”
People of Michigan v. Evan Taylor Armogeda (Mich. Ct. App. 2024).
— Mich. Comp. Laws § 777.52(2) — 7 cases
People v. Crews, 829 N.W.2d 898 (Mich. Ct. App. 2013). “51, PRV 2, MCL 777.52, and PRV 5, MCL 777.55. Specifically, defendant argued that PRV 1 was improperly scored because his convictions for burglaries in Ohio did not correspond to any Michigan felonies and, accordingly, could not be used as prior high-severity offenses under PRV…”
People of Michigan v. Isaiah Buckner (Mich. Ct. App. 2021). “52(2), a “prior low severity felony conviction” means a conviction entered before the sentencing offense was committed that falls within the categories provided in MCL 777.”
People of Michigan v. Jamal Devonta Bennett (Mich. Ct. App. 2024).
People of Michigan v. Moses Richard Emmanuel (Mich. Ct. App. 2026). “PRV 2 is contained in MCL 777.52, which provides as follows: (1) Prior record variable 2 is prior low severity felony convictions.”
People of Michigan v. Kenneth Anthony Taylor (Mich. Ct. App. 2015).
— Mich. Comp. Laws § 777.52(2)(a) — 6 cases
People of Michigan v. Michael James Scandalito (Mich. Ct. App. 2022).
People of Michigan v. Malcolm Dwayne Haynes (Mich. Ct. App. 2024).
Mott 193734 v. Rewerts (W.D. Mich. 2023).
People of Michigan v. Ronald Johnson (Mich. Ct. App. 2014).
People of Michigan v. Paul Peter Gross (Mich. Ct. App. 2015).
— Mich. Comp. Laws § 777.52(2)(b) — 5 cases
People v. Meeks, 293 Mich. App. 115 (Mich. Ct. App. 2011). “MCL 777.52(1)(d) prescribes the assessment of five points when the defendant has one prior low-severity felony conviction.”
People of Michigan v. Moses Richard Emmanuel (Mich. Ct. App. 2026). “PRV 2 is contained in MCL 777.52, which provides as follows: (1) Prior record variable 2 is prior low severity felony convictions.”
People of Michigan v. Regan Adam Reynolds (Mich. Ct. App. 2016).
People of Michigan v. Deandre Harris (Mich. Ct. App. 2020).
People of Michigan v. Leon Cavanaugh Jr (Mich. Ct. App. 2025).
— Mich. Comp. Laws § 777.52(2)(c) — 2 cases
People of Michigan v. Paul Peter Gross (Mich. Ct. App. 2015).
People of Michigan v. Darrius Lavelle Brown (Mich. Ct. App. 2015).
— Mich. Comp. Laws § 777.52(l)(a) — 1 case
People v. Marshall, 830 N.W.2d 414 (Mich. Ct. App. 2012). “Further, the conviction information section of the sentencing information report listed “4th or subsequent” in the space for habitual-offender information and listed a score of 30 points for prior record variable 2, indicating that defendant has four or more prior, low-severity…”
— Mich. Comp. Laws § 777.52(l)(b) — 1 case
People v. Harper, 739 N.W.2d 523 (Mich. 2007). “51; MCL 777.52; MCL 777.55. [7] MCL 777.46(1)(c).”
— Mich. Comp. Laws § 777.52(l)(e) — 1 case
People v. Young, 740 N.W.2d 347 (Mich. Ct. App. 2007). “51, MCL 777.52, MCL 777.53, MCL 777.54, and MCL 777.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.