People of Michigan v. Erick Rosean Allen

Summary

The Court held that a parolee is entitled to jail credit for time spent in jail before the Michigan Department of Corrections files a parole detainer, when the detention resulted from the defendant's inability to furnish bond on the new charge. The entitlement ends when the detainer is filed because detention thereafter rests on the parole violation rather than the new criminal charge. Because the unpreserved denial of 17 days of mandatory credit was plain error affecting substantial rights, the Court reversed, vacated the sentence, and remanded for resentencing.