concurrent sentence rule (Michigan) · Go Syfert
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concurrent sentence rule in Michigan

10 Michigan opinions name it 2 courts 1986–2026 4 in the last five years

The cases below were cited by Michigan courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (1)

CaseFollowedCited
People v. Binieckigreen
michctapp · 1971 · cited in 1 Michigan opinions naming this issue, 2001–2001
2 sentences

2001See also People v Biniecki, 35 Mich App 335, 336-337 ; 192 NW2d 638 (1971) (language of escape statute “clearly requires a consecutive sentence . . .”); People v Bachman; 50 Mich App 682, 686 ; 213 NW2d 800 (1973) (in MCL 750.193 “the Legislature unambigu ously directed that [a] sentence for prison escape commence at the completion of any former sentences ‘then being served’ ”); People v Pruitt, 23 Mich App 510, 516 ; 179 NW2d 22 (1970) (language of § 193 indicates that a sentence for conviction under this statute is “an exception to the concurrent sentence requirement . . .”); People v Andrew

2001See also People v Biniecki, 35 Mich App 335, 336-337 ; 192 NW2d 638 (1971) (language of escape statute “clearly requires a consecutive sentence . . .”); People v Bachman; 50 Mich App 682, 686 ; 213 NW2d 800 (1973) (in MCL 750.193 “the Legislature unambigu ously directed that [a] sentence for prison escape commence at the completion of any former sentences ‘then being served’ ”); People v Pruitt, 23 Mich App 510, 516 ; 179 NW2d 22 (1970) (language of § 193 indicates that a sentence for conviction under this statute is “an exception to the concurrent sentence requirement . . .”); People v Andrew

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Michigan. Read the followed side critically anyway.

Also cited on this issue (11)

CaseCitedYears
People v. Prieskorn green
mich · 1986
2 sentences

2026Additionally, the Supreme Court ruled that confining jail credit to the offense for which the defendant was convicted did not violate the concurrent sentence rule, as long as the trial court did not impose the sentence “to commence at the completion or expiration of another sentence.” Id. at 342 .

2026Additionally, the Supreme Court ruled that confining jail credit to the offense for which the defendant was convicted did not violate the concurrent sentence rule as long as the trial court did not impose the sentence “to commence at the completion or expiration of another sentence.” Id. at 342 .

51998–2026
People v. Givans green
michctapp · 1998
2 sentences

2026This Court added that the concurrent-sentence rule, i.e., the rule prohibiting consecutive sentences unless statutorily authorized, was not implicated “because commencement of the sentence in this case was not delayed until the completion of the sentence in the [other] case . . . .” Id.

2026“Under the concurrent sentence rule, one sentence may not be ordered to begin at the completion of another sentence unless statutory authority provides otherwise.” People v Givans, 227 Mich App 113, 126 ; 575 NW2d 84 (1997).

32015–2026
In Re Carey green
mich · 1964
2 sentences

1989The concurrent sentence rule provides that "in the absence of statutory authority, a sentence may not be imposed to commence at the completion or expiration of another sentence.” In re Carey, 372 Mich 378, 380 ; 126 NW2d 727 (1964).

1989The concurrent sentence rule provides that "in the absence of statutory authority, a sentence may not be imposed to commence at the completion or expiration of another sentence.” In re Carey, 372 Mich 378, 380 ; 126 NW2d 727 (1964).

21986–1989
People v. Idziak green
mich · 2009
1 sentence

2026In Idziak, the issue before our Supreme Court was “whether a parolee who is convicted and sentenced to a term of imprisonment for a felony committed while on parole is entitled, under Michigan’s jail credit statute, MCL 769.11b, to credit for time served in jail after his arrest on the new offense and before sentencing for that offense.” Idziak, 484 Mich at 552 .

12026–2026
People v. Adkins green
mich · 1989
1 sentence

2020Adkins, 433 Mich at 749 , quoting Prieskorn, 424 Mich at 342 .

12020–2020
People v. Passalacqua neutral
michctapp · 1973
2 sentences

2001In People v Passalacqua, 48 Mich App 634, 635 ; 211 NW2d 59 (1973), a panel of this Court opined: The punishment for the offense of prison escape is an exception to the concurrent sentence requirement.

2001In People v Passalacqua, 48 Mich App 634, 635 ; 211 NW2d 59 (1973), a panel of this Court opined: The punishment for the offense of prison escape is an exception to the concurrent sentence requirement.

12001–2001
People v. ANDREWS 2 neutral
michctapp · 1974
2 sentences

2001See also People v Biniecki, 35 Mich App 335, 336-337 ; 192 NW2d 638 (1971) (language of escape statute “clearly requires a consecutive sentence . . .”); People v Bachman; 50 Mich App 682, 686 ; 213 NW2d 800 (1973) (in MCL 750.193 “the Legislature unambigu ously directed that [a] sentence for prison escape commence at the completion of any former sentences ‘then being served’ ”); People v Pruitt, 23 Mich App 510, 516 ; 179 NW2d 22 (1970) (language of § 193 indicates that a sentence for conviction under this statute is “an exception to the concurrent sentence requirement . . .”); People v Andrew

2001See also People v Biniecki, 35 Mich App 335, 336-337 ; 192 NW2d 638 (1971) (language of escape statute “clearly requires a consecutive sentence . . .”); People v Bachman; 50 Mich App 682, 686 ; 213 NW2d 800 (1973) (in MCL 750.193 “the Legislature unambigu ously directed that [a] sentence for prison escape commence at the completion of any former sentences ‘then being served’ ”); People v Pruitt, 23 Mich App 510, 516 ; 179 NW2d 22 (1970) (language of § 193 indicates that a sentence for conviction under this statute is “an exception to the concurrent sentence requirement . . .”); People v Andrew

12001–2001
People v. Bachman green
michctapp · 1973
2 sentences

2001See also People v Biniecki, 35 Mich App 335, 336-337 ; 192 NW2d 638 (1971) (language of escape statute “clearly requires a consecutive sentence . . .”); People v Bachman; 50 Mich App 682, 686 ; 213 NW2d 800 (1973) (in MCL 750.193 “the Legislature unambigu ously directed that [a] sentence for prison escape commence at the completion of any former sentences ‘then being served’ ”); People v Pruitt, 23 Mich App 510, 516 ; 179 NW2d 22 (1970) (language of § 193 indicates that a sentence for conviction under this statute is “an exception to the concurrent sentence requirement . . .”); People v Andrew

2001See also People v Biniecki, 35 Mich App 335, 336-337 ; 192 NW2d 638 (1971) (language of escape statute “clearly requires a consecutive sentence . . .”); People v Bachman; 50 Mich App 682, 686 ; 213 NW2d 800 (1973) (in MCL 750.193 “the Legislature unambigu ously directed that [a] sentence for prison escape commence at the completion of any former sentences ‘then being served’ ”); People v Pruitt, 23 Mich App 510, 516 ; 179 NW2d 22 (1970) (language of § 193 indicates that a sentence for conviction under this statute is “an exception to the concurrent sentence requirement . . .”); People v Andrew

12001–2001
People v. Pruitt green
michctapp · 1970
2 sentences

2001See also People v Biniecki, 35 Mich App 335, 336-337 ; 192 NW2d 638 (1971) (language of escape statute “clearly requires a consecutive sentence . . .”); People v Bachman; 50 Mich App 682, 686 ; 213 NW2d 800 (1973) (in MCL 750.193 “the Legislature unambigu ously directed that [a] sentence for prison escape commence at the completion of any former sentences ‘then being served’ ”); People v Pruitt, 23 Mich App 510, 516 ; 179 NW2d 22 (1970) (language of § 193 indicates that a sentence for conviction under this statute is “an exception to the concurrent sentence requirement . . .”); People v Andrew

2001See also People v Biniecki, 35 Mich App 335, 336-337 ; 192 NW2d 638 (1971) (language of escape statute “clearly requires a consecutive sentence . . .”); People v Bachman; 50 Mich App 682, 686 ; 213 NW2d 800 (1973) (in MCL 750.193 “the Legislature unambigu ously directed that [a] sentence for prison escape commence at the completion of any former sentences ‘then being served’ ”); People v Pruitt, 23 Mich App 510, 516 ; 179 NW2d 22 (1970) (language of § 193 indicates that a sentence for conviction under this statute is “an exception to the concurrent sentence requirement . . .”); People v Andrew

12001–2001
Miranda v. Arizona green
scotus · 1966
2 sentences

1998Affirmed. 1 People v Walker (On Rehearing), 374 Mich 331 ; 132 NW2d 87 (1965). 2 Miranda v Arizona, 384 US 436 ; 86 S Ct 1602 ; 16 L Ed 2d 694 (1966).

1998Affirmed. 1 People v Walker (On Rehearing), 374 Mich 331 ; 132 NW2d 87 (1965). 2 Miranda v Arizona, 384 US 436 ; 86 S Ct 1602 ; 16 L Ed 2d 694 (1966).

11998–1998
People v. Walker green
mich · 1965
2 sentences

1998Affirmed. 1 People v Walker (On Rehearing), 374 Mich 331 ; 132 NW2d 87 (1965). 2 Miranda v Arizona, 384 US 436 ; 86 S Ct 1602 ; 16 L Ed 2d 694 (1966).

1998Affirmed. 1 People v Walker (On Rehearing), 374 Mich 331 ; 132 NW2d 87 (1965). 2 Miranda v Arizona, 384 US 436 ; 86 S Ct 1602 ; 16 L Ed 2d 694 (1966).

11998–1998

Statutes the citing opinions construe

MI § Mich. Comp. Laws § 769.11b (9) MI § Mich. Comp. Laws § 769.1 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

WA 13 (1981–2007) MI 10 (1986–2026) FL 9 (1977–2018) MO 9 (1980–2018) WY 4 (1988–1989) TX 4 (1970–2019) MD 3 (1969–1982) IL 3 (1996–2001) CA 2 (1967–2014) GA 2 (1975–1979) DE 2 (1995–1995) WI 2 (1978–1978) PA 2 (1972–1975)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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