People v. Hellis

In People v. Hellis, 211 Mich App 634, 650-651; 536 NW2d 587 (1995), the Court upheld a deviation below the minimum sentence where the defendant was convicted of delivery of more than 50 but less than 225 grams of cocaine due to his post-arrest "drastic change in lifestyle." The trial court cited completion of an eighteen-day outpatient drug treatment program, weekly outpatient sessions, extensive community service, and the defendant's apparent abstention from controlled substances, and deviated despite the defendant's fourteen-year history of drug related criminal activity. The Court found that, under these circumstances, the trial court did not abuse its discretion. Id.