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

Mich. Comp. Laws § 777.54 (2026)

Prior low severity juvenile adjudications.

✓ current as of July 2026
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THE CODE OF CRIMINAL PROCEDURE


Act 175 of 1927


777.54 Prior low severity juvenile adjudications.

Sec. 54.

    (1) Prior record variable 4 is prior low severity juvenile adjudications. Score prior record variable 4 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 6 or more prior low severity juvenile adjudications

    20 points

    (b) The offender has 5 prior low severity juvenile adjudications

    15 points

    (c) The offender has 3 or 4 prior low severity juvenile adjudications

    10 points

    (d) The offender has 2 prior low severity juvenile adjudications

    5 points

    (e) The offender has 1 prior low severity juvenile adjudication

    2 points

    (f) The offender has no prior low severity juvenile adjudications

    0 points

    (2) As used in this section, "prior low severity juvenile adjudication" means a juvenile adjudication for conduct that would be any of the following if committed by an adult, if the order of disposition 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 corresponding 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. 2000, Act 279, Eff. Oct. 1, 2000 ;-- Am. 2006, Act 655, Imd. Eff. Jan. 9, 2007

Notes of Decisions
Cited in 23 cases (5 in the last 5 years), 2007–2025 · leading case: People v. Butler, 892 N.W.2d 6 (Mich. Ct. App. 2016).
Sort: Relevance Newest Treatment
People v. Butler, 892 N.W.2d 6 (Mich. Ct. App. 2016). · cites it 2× “51 through MCL 777.54, consider the nature of the defendant’s prior crimes and whether they are worthy of being scored under the sentencing guidelines, and points are to be assessed based on the number and severity of those offenses.”
People v. Young, 740 N.W.2d 347 (Mich. Ct. App. 2007). “53, MCL 777.54, and MCL 777.55. In addition, under MCL 777.”
People v. Billings, 770 N.W.2d 893 (Mich. Ct. App. 2009). “3 Shively first argues that prior record variable (PRV) 4, MCL 777.54, was improperly scored at 10 points for adjudications in 1975 and 1978.”
People v. Crews, 829 N.W.2d 898 (Mich. Ct. App. 2013). “53, and MCL 777.54, which mirror MCL 777.51 and respectively address the scoring of PRV 2, PRV 3, and PRV 4, do not define the term “corresponding.”
People v. Luckett, 777 N.W.2d 163 (Mich. 2010). · cites it 2× “53 (PRV 3 is scored for prior high severity juvenile adjudications); MCL 777.54 (PRV 4 is scored for prior low severity juvenile adjudications); MCL 777.”
People v. Young, 740 N.W.2d 347 (Mich. Ct. App. 2007). “53, MCL 777.54, and MCL 777.55. In addition, under MCL 777.”
People of Michigan v. Kelvin Michael Dequan Coats (Mich. Ct. App. 2016). · cites it 6× “Defendant asserts that he has only two prior juvenile adjudications and should be assessed only five points for PRV 4.”
People of Michigan v. Jalen Rashaad Conner (Mich. Ct. App. 2016). · cites it 4× “In contrast, when “[t]he offender has no prior low severity juvenile adjudications,” PRV 4 must be assessed at zero points.”
People of Michigan v. Rodney Charles Butler (Mich. Ct. App. 2016). · cites it 2× “51 through MCL 777.54, consider the nature of the defendant’s prior crimes, whether they are worthy of being scored under the sentencing guidelines, and the points to be assessed based upon the number and severity of those offenses.”
People of Michigan v. Kesia Dionna Malone (Mich. Ct. App. 2019). · cites it 2× “First, Malone’s two juvenile adjudications were considered under MCL 777.54, which addresses prior low severity juvenile adjudications.”
People of Michigan v. Isaiah Buckner (Mich. Ct. App. 2021). · cites it 2× “MCL 777.54(1). A court should assess 20 points for PRV 4 if the “offender has 6 or more prior low severity juvenile adjudications.”
People of Michigan v. Joseph Lee Gilmore (Mich. Ct. App. 2015). · cites it 3× “Because the discharge date of each juvenile offense occurred within 10 -9- years of the commission date of each subsequent offense, defendant’s juvenile history includes three offenses that meet the statutory requirements for PRV 4 listed in MCL 777.”
Show all 23 citing cases →
— Mich. Comp. Laws § 777.54(1) — 4 cases
People of Michigan v. Jalen Rashaad Conner (Mich. Ct. App. 2016). “In contrast, when “[t]he offender has no prior low severity juvenile adjudications,” PRV 4 must be assessed at zero points.”
People of Michigan v. Isaiah Buckner (Mich. Ct. App. 2021). “MCL 777.54(1). A court should assess 20 points for PRV 4 if the “offender has 6 or more prior low severity juvenile adjudications.”
People of Michigan v. Deshaun Lamar Bounds (Mich. Ct. App. 2025).
People of Michigan v. Joseph Lee Gilmore (Mich. Ct. App. 2015). “Because the discharge date of each juvenile offense occurred within 10 -9- years of the commission date of each subsequent offense, defendant’s juvenile history includes three offenses that meet the statutory requirements for PRV 4 listed in MCL 777.”
— Mich. Comp. Laws § 777.54(1)(a) — 1 case
People of Michigan v. Isaiah Buckner (Mich. Ct. App. 2021). “MCL 777.54(1). A court should assess 20 points for PRV 4 if the “offender has 6 or more prior low severity juvenile adjudications.”
— Mich. Comp. Laws § 777.54(1)(c) — 3 cases
People of Michigan v. Kelvin Michael Dequan Coats (Mich. Ct. App. 2016). “Defendant asserts that he has only two prior juvenile adjudications and should be assessed only five points for PRV 4.”
People of Michigan v. Dejhan Quenzelle Sanders (Mich. Ct. App. 2021).
People of Michigan v. Joseph Lee Gilmore (Mich. Ct. App. 2015). “Because the discharge date of each juvenile offense occurred within 10 -9- years of the commission date of each subsequent offense, defendant’s juvenile history includes three offenses that meet the statutory requirements for PRV 4 listed in MCL 777.”
— Mich. Comp. Laws § 777.54(1)(d) — 5 cases
People of Michigan v. Kelvin Michael Dequan Coats (Mich. Ct. App. 2016). “Defendant asserts that he has only two prior juvenile adjudications and should be assessed only five points for PRV 4.”
People of Michigan v. Andrew Eric Lindahl (Mich. Ct. App. 2018).
People of Michigan v. Andrew Eric Lindahl (Mich. Ct. App. 2018).
People of Michigan v. Kesia Dionna Malone (Mich. Ct. App. 2019). “First, Malone’s two juvenile adjudications were considered under MCL 777.54, which addresses prior low severity juvenile adjudications.”
People of Michigan v. Paul Peter Gross (Mich. Ct. App. 2015).
— Mich. Comp. Laws § 777.54(1)(e) — 2 cases
People of Michigan v. Jalen Rashaad Conner (Mich. Ct. App. 2016). “In contrast, when “[t]he offender has no prior low severity juvenile adjudications,” PRV 4 must be assessed at zero points.”
People of Michigan v. Donell Willie-Terrell Ivey (Mich. Ct. App. 2024).
— Mich. Comp. Laws § 777.54(1)(f) — 1 case
People of Michigan v. Jalen Rashaad Conner (Mich. Ct. App. 2016). “In contrast, when “[t]he offender has no prior low severity juvenile adjudications,” PRV 4 must be assessed at zero points.”
— Mich. Comp. Laws § 777.54(2) — 1 case
People of Michigan v. Jalen Rashaad Conner (Mich. Ct. App. 2016). “In contrast, when “[t]he offender has no prior low severity juvenile adjudications,” PRV 4 must be assessed at zero points.”
— Mich. Comp. Laws § 777.54(2)(a) — 2 cases
People of Michigan v. Kelvin Michael Dequan Coats (Mich. Ct. App. 2016). “Defendant asserts that he has only two prior juvenile adjudications and should be assessed only five points for PRV 4.”
People of Michigan v. Paul Peter Gross (Mich. Ct. App. 2015).
— Mich. Comp. Laws § 777.54(2)(c) — 1 case
People of Michigan v. Paul Peter Gross (Mich. Ct. App. 2015).
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