People of Michigan v. Joseph James Chandler, 331031

Joseph Chandler pleaded guilty to manufacture of methamphetamine, maintaining a meth lab, and possession of methamphetamine; sentenced to concurrent terms (two 6–30 year terms and 35 days).
Offenses occurred April 2012; arraigned July 2014; posted bond and was released.
Chandler was arrested on unrelated charges in another county on March 23, 2015, remained incarcerated there, and later pleaded guilty in that other case.
His bond in the present (Cass County) case was revoked on June 9, 2015; sentencing in the Cass County case occurred July 10, 2015.
Trial court awarded 35 days’ jail credit (3 days from July 11–14, 2014, and 32 days from June 9–July 10, 2015) but denied credit for the March 23–June 9 period because that incarceration was for unrelated charges. Defendant did not object at sentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether defendant was entitled to presentence jail credit for time incarcerated on unrelated charges (Mar 23–Jun 9, 2015)	People: credit limited to time jailed "for the offense of which he is convicted"; unrelated incarceration not creditable	Chandler: sought credit for entire period of pre-sentencing incarceration, including time jailed on unrelated charges	Court held no; credit only for time jailed because of inability to post bond on the convicted offense; unrelated incarceration not creditable
Whether trial counsel was ineffective for failing to object to jail-credit calculation	People: counsel not ineffective where objection would be meritless and record shows timely bond revocation	Chandler: counsel should have objected to secure additional jail credit	Court held no ineffective assistance; failure to object would have been meritless and record lacks evidence counsel knew earlier about the other-county incarceration

People v Meshell, 265 Mich. App. 616 (court reviews unpreserved sentencing errors for plain error)
People v Adkins, 433 Mich. 732 (credit only for presentence jail time served because defendant was denied or unable to furnish bond for the offense of conviction)
People v Givans, 227 Mich. App. 113 (defendant not entitled to credit for incarceration on another offense)
People v Prieskorn, 424 Mich. 327 (delay in charging does not entitle defendant to credit for unrelated incarceration)
People v Waclawski, 286 Mich. App. 634 (no credit for time jailed in another state for unrelated offense despite extradition delay)
People v Rodriguez, 212 Mich. App. 351 (counsel not ineffective for failing to raise meritless objections)