People v. Lown, 488 Mich. 242

Background

This case clarifies the Michigan statutory 180‑day rule (MCL 780.131 and 780.133) governing dismissal of cases where inmates are imprisoned with pending charges.
The rule requires dismissal if action on the charges is not commenced within 180 days after the DOC delivers notice of imprisonment to the prosecutor.
The 180‑day period is a fixed, consecutive 180 days starting the day after notice is received, not a rolling or apportionable count.
Commencement of action within the 180 days is sufficient; trial need not begin or end within that period.
There is no judicially created good‑faith exception to the rule, though good‑faith action to move toward readiness for trial is a recognized component of compliance.
In the analyzed case, the prosecutor began action within the 180 days and remained ready for trial thereafter; the appellate courts affirmed under the majority view.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the 180‑day rule jurisdictional and when must dismissal occur?	Lown argues the rule is jurisdictional and mandates dismissal if action isn’t commenced within 180 days.	The rule is jurisdictional but requires action commenced within 180 days; delays may occur but do not automatically trigger dismissal.	Rule is jurisdictional for personal jurisdiction; dismissal required only if action isn’t commenced within 180 days; delays may be excused if action was commenced in good faith and later delays are excusable.
How should the 180‑day period be calculated and are delays attributed to parties?	The period should reflect days attributable to the prosecution, court, and others to assess if 180 days expired.	The 180‑day period is a fixed consecutive term beginning after notice; delays may be explained but should not be apportioned to determine compliance.	The 180‑day period is a fixed 180 consecutive days; it is not calculated by apportioning delays among parties; delays may be considered for good‑faith action but do not alter the fixed period.
Does good‑faith action by the prosecutor create an extrastatutory exception to the 180‑day rule?	Hendershot’s good‑faith discussion creates an exception allowing delays within the period without dismissal.	There is no statutory good‑faith exception; good‑faith action is an implicit component within the 180‑day framework.	There is no extrastatutory good‑faith exception; good‑faith action is part of satisfying the rule, not an exception to it.
What is the proper interpretation of ‘action’ under the 180‑day rule and its precedential impact?	Action may be broader than mere commencement of trial, encompassing steps toward readiness.	Action means commencement within 180 days; preparation alone cannot postpone the need to commence the action.	‘Action’ within 180 days means commencement toward bringing the case to trial; readiness alone suffices if promptly pursued within the period, but mere preliminary steps followed by delay may trigger dismissal.

Key Cases Cited

People v Hendershot, 357 Mich 300 (1959) (established the good‑faith/action concept within the 180‑day rule and that trial need not occur within 180 days to preserve jurisdiction)
People v Williams, 475 Mich 245 (2006) (overruled aspects of prior 180‑day interpretations; clarified statutory language alignment with 180‑day rule)
People v England, 177 Mich App 279 (1989) (analyzed delay attribution concepts relevant to speedy trial discussions in context of the 180‑day rule)
People v Davis, 283 Mich App 737 (2009) (adopted the notion that 180‑day compliance hinges on prompt action to readiness, not merely calendar days)
People v Chavies, 234 Mich App 274 (1999) (precedent cited by trial court prior to Williams; addressed 180‑day rule applicability)