Makowski v. Granholm: Makowski was convicted of first degree murder but was granted a commutation for his sentence. A commutation is a lessoning of punishment and is usually conditional. The Governor approved, signed the commutation, and delivered it to the Secretary of the State. Days later, the Governor regretted her decision, revoked the commutation, destroyed all evidence of its existence, and informed Makowski of the reinstatement of his original statement. Makowski filed suit against the Governor and the Secretary on the grounds that the revocation and their acts were unconstitutional.