Woman to be resentenced in 2021 Monroe carjacking case

MONROE — An error made in calculating a minimum sentence range in a 2021 carjacking case means a defendant has a chance at a new sentence.

Michelle Ann Holladay, 42, appealed her sentences on carjacking and felonious assault charges. A Michigan Court of Appeals panel agreed to part of her arguments and sent the case back to Monroe County Circuit Court for resentencing.

Holladay pleaded no contest to carjacking and felonious assault for her role in the armed theft of a vehicle from a grandmother with two children on Aug. 3, 2021, at a hotel on North Dixie Highway near Interstate 75 in Monroe. She and an accomplice, William Lanham, had started a crime spree in Kentucky. After stealing the vehicle at gunpoint, they headed north.

A tipster called 911 to report seeing the stolen vehicle entering a rest area near Holly Road on northbound I-75 in Oakland County. Michigan State Police troopers spotted the vehicle and attempted to stop it, but Lanham and Holladay fled, exiting the freeway at Holly Road.

“During the pursuit, Lanham and defendant’s vehicle struck two other occupied vehicles and a cyclist on the road before being forced to stop,” the opinion written by Judges Christopher M. Murray, Thomas C. Cameron and Sima G. Patel said. “Lanham and defendant then ran into a nearby house, forced the occupants out, and then barricaded themselves inside. Police surrounded the house, and Lanham fired several rounds with his gun at the police outside. After some time, defendant surrendered to the police, and Lanham was then found dead inside the home from a self-inflicted gunshot wound.”

At the sentencing in March 2022, the sentencing guidelines to determine the low end of the sentence range were calculated at 108 to 180 months for the carjacking charge and 2 to 17 months for the felonious assault charge. Holladay’s trial attorney, John Gonta, objected to two of the offense variables (OVs) used in the calculation. One variable concerned a defendant’s continuing pattern of criminal behavior. The other concerned a defendant’s interference with the administration of justice or emergency services.

Circuit Judge Daniel S. White sentenced Holladay to 108 to 360 months in prison for the carjacking conviction and 1 year in jail for the felonious assault conviction.

Holladay’s appeal challenged the scoring of the two OVs that Gonta objected to at sentencing along with four others. The appeals court found that the two that were objected to and three others were scored correctly.

The one offense variable the appeals court found was scored incorrectly, OV 4, involves psychological injury to the victims of the offense. The judges wrote that there was insufficient evidence to show the woman whose car was stolen or anyone else suffered a serious psychological injury requiring professional treatment. The county’s victim’s advocate tried unsuccessfully to contact the woman to obtain a victim impact statement. The woman also did not give a statement at the sentencing nor did she otherwise testify about the carjacking. The prosecution also agreed that this variable should have been scored at zero due to a lack of a factual basis to support a psychological injury.

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Holladay, through her appellate attorney Ann LaBreck of the Michigan State Appellate Defender Office, also argued she received ineffective advice of counsel for not objecting to the four offense variables included in the appeal along with the two that Gonta objected to.

“We agree that defendant’s trial counsel’s performance was ineffective for failing to object to the scoring of OV 4,” the judges wrote.

Not recognizing the lack of evidence to support a finding of serious psychological injury led to the “reasonable probability that, had defendant’s trial counsel objected to the scoring of OV 4, the outcome of defendant’s carjacking sentence would have been different,” the judges wrote.

Removing the points for OV 4 reduces the minimum sentence range to 81 to 135 months on the carjacking charge.

The incorrect scoring of OV 4 on the felonious assault charge did not affect that minimum sentence calculation, the judges said.

A new sentencing date has not been scheduled, according to online court records.

Holladay is incarcerated at Women’s Huron Valley Correctional Facility near Ypsilanti.

— Contact reporter David Panian at dpanian@lenconnect.com or follow him on X, formerly Twitter: @lenaweepanian.

This article originally appeared on The Monroe News: Michigan Court of Appeals orders new sentence in carjacking case