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The MDOC in a NutshellThe MDOC in a NutshellStuart G. Friedman

Attorney at Law

843 Penniman Avenue

Plymouth, MI 48170

(734) 662-4070

stu@crimapp.com

Kathleen Schaefer

Parole & Probation Consulting

2632 Buhl Building

Detroit, MI 48226

(313) 882-6178

schaefkm@comcast.net

OverviewOverview

Prisoner Intake into the MDOCPrisoner Intake into the MDOCCommon Custody IssuesCommon Custody IssuesParole ProcessParole ProcessParole Revocation Parole Revocation Alternative Release ProgramsAlternative Release Programs

Our Cyber HandoutOur Cyber Handout

MDOC Phone DirectoryMDOC Phone DirectoryPolicy DirectivesPolicy DirectivesParole Guidelines Scoring MemoParole Guidelines Scoring MemoSelected CasesSelected CasesSample MDOC FormsSample MDOC Forms

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Further InformationFurther Information

Prison Legal Services of MichiganPrison Legal Services of MichiganCDCD--ROM DiscROM Disc

MDOCMDOChttp://www.michigan.gov/correctionshttp://www.michigan.gov/corrections

American Friends Service CommitteeAmerican Friends Service CommitteeCAPPsCAPPs ((““the other the other CAPPsCAPPs””))

http://www.cappshttp://www.capps--mi.org/mi.org/

Law Governing MDOCLaw Governing MDOC

Constitutions

Statutes

Administrative RulesPolicy Directives

IntakeIntake

Judgment of SentenceJudgment of SentencePSIPSIParole Guideline Data Entry Form Parole Guideline Data Entry Form Jail RecordJail Record

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The PSIThe PSI

The PSI is the Most Critical Document in The PSI is the Most Critical Document in the Inmatethe Inmate’’s File;s File;It Must be Accurate;It Must be Accurate;The PSI is relied on for Decisions involving The PSI is relied on for Decisions involving Program and Security Classification, Parole Program and Security Classification, Parole Board Interviews and Parole Decisions;Board Interviews and Parole Decisions;It is Exceptionally Difficult to Challenge It is Exceptionally Difficult to Challenge the PSI After Sentencing!!!the PSI After Sentencing!!!

PSI TipsPSI TipsClients should bring the following to PSI Interview:Clients should bring the following to PSI Interview:

DriverDriver’’s License or other valid picture IDs License or other valid picture IDBirth CertificateBirth CertificateSocial Security CardSocial Security CardPay Stub or other Proof of EmploymentPay Stub or other Proof of EmploymentProof of Monthly State Assistance Information (ADC,SSI, etc.)Proof of Monthly State Assistance Information (ADC,SSI, etc.)Diploma or G.E.D. and/or current report cardDiploma or G.E.D. and/or current report cardLetters verifying dates of substance abuse/mental health counselLetters verifying dates of substance abuse/mental health counseling ing (if applicable)(if applicable)Letters, prescription records for medical condition (if applicabLetters, prescription records for medical condition (if applicable)le)AA/NA attendance sheets (if applicable)AA/NA attendance sheets (if applicable)Proof of Military Service (if applicable)Proof of Military Service (if applicable)

QuarantineQuarantine

Initial Placement in the MDOCInitial Placement in the MDOCCharles Charles EgelerEgeler for Men; Scott for Women;for Men; Scott for Women;HYTA Commitments HYTA Commitments –– Thumb for MenThumb for MenUP Commitments UP Commitments -- Marquette Branch Prison Marquette Branch Prison (Men Only);(Men Only);

Risk ScreeningRisk ScreeningProgram ClassificationProgram ClassificationPhysical and Physical and Mental EvaluationMental Evaluation

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Security Level Classification Security Level Classification

Security Level Classification Security Level Classification –– screening is screening is done to determine management and done to determine management and confinement requirements. confinement requirements. The PSI is used as a tool in the screening The PSI is used as a tool in the screening

process.process.Levels I Levels I –– VI and Segregation. Level I is VI and Segregation. Level I is least secure. Segregation is most secure. least secure. Segregation is most secure.

Program ClassificationProgram Classification

Program Classification Program Classification –– screening is done screening is done to identify needs, interests and abilities for to identify needs, interests and abilities for work, school assignments and referrals to work, school assignments and referrals to programs.programs.

Risk ScreeningRisk Screening

AssaultiveAssaultive Offender Offender Property RiskProperty RiskRisk Factors are Slightly Different for Male Risk Factors are Slightly Different for Male and Female Prisonersand Female Prisoners

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History of Violent CrimesHistory of Violent Crimes

Not Eligible for Special Security Not Eligible for Special Security Assignments;Assignments;Serving for or Having a History of Violent Serving for or Having a History of Violent Crimes Within the Last 5 yearsCrimes Within the Last 5 years

Files Created on OffenderFiles Created on Offender

Central Office;Central Office;Facility/Counselor File;Facility/Counselor File;Parole Office/Field File;Parole Office/Field File;Medical/PsychologicalMedical/Psychological

Obtaining an InmateObtaining an Inmate’’s Files File

Available Under FOIA;Available Under FOIA;Request Cannot Come from an Inmate;Request Cannot Come from an Inmate;

InmateInmate’’s Privacy Waiver Increases What s Privacy Waiver Increases What Material You Can Get;Material You Can Get;Psychological Assessments and Reports are Psychological Assessments and Reports are kept in the Medical File in the Health Care kept in the Medical File in the Health Care UnitUnit

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Get an InmateGet an Inmate’’s File Three Timess File Three Times

90 Days After Entry into System;90 Days After Entry into System;1 Year Before Parole;1 Year Before Parole;After a Flop (Be Sure to Expressly Request After a Flop (Be Sure to Expressly Request Board Notes)Board Notes)

GEDGEDInmates with 2 year sentences Inmates with 2 year sentences or higher must get a GED or higher must get a GED (assuming no high school (assuming no high school diploma);diploma);Cannot Get a Parole Without Cannot Get a Parole Without GED unless there is a waiver;GED unless there is a waiver;Waivers are Possible. It is Waivers are Possible. It is Important to Get Histories of Important to Get Histories of Learning Disabilities to the Learning Disabilities to the MDOC as Quickly as Possible.MDOC as Quickly as Possible.

SAI (SAI (““Boot CampBoot Camp””) Eligibility) EligibilityNo prior state prison sentence;No prior state prison sentence;No pending felony No pending felony detainerdetainerand not felony suspect;and not felony suspect;Not previously placed in SAI Not previously placed in SAI unless the discharge was for unless the discharge was for medical reasonsmedical reasonsPhysically or Mental Handicap Physically or Mental Handicap able to participateable to participateNo prior federal prison No prior federal prison sentence;sentence;Is serving an indeterminate Is serving an indeterminate sentence or sentences with sentence or sentences with minimum sentence of 36 minimum sentence of 36 months or less, except months or less, except 750.110/110a is with a 24 750.110/110a is with a 24 month minimum or less;month minimum or less;

Does not screen very Does not screen very high or potentially very high or potentially very high assault risk;high assault risk;Does not have a true Does not have a true security level of IV or V;security level of IV or V;Would likely have been Would likely have been sentenced to prison and sentenced to prison and is not being sentenced for is not being sentenced for an offense listed in an offense listed in Attachment B or an Attachment B or an attempt to commit one of attempt to commit one of those offenses.those offenses.

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SAI Excluded Offenses SAI Excluded Offenses (PD(PD--DWA 05.01.142)DWA 05.01.142)

Not serving for an Not serving for an ineligible offense (refer to ineligible offense (refer to PD 05.01.142 Attachment PD 05.01.142 Attachment A);A);Does not have a prior or Does not have a prior or current conviction for an current conviction for an offense listed in PD offense listed in PD 05.01.142 Attachment B;05.01.142 Attachment B;Is not serving a sentence Is not serving a sentence for any offense involving for any offense involving a death, including a death, including Negligent Homicide;Negligent Homicide;

If serving a sentence for If serving a sentence for a violation of .7401 or a violation of .7401 or .7403 of the SCA, must .7403 of the SCA, must have served the statutory have served the statutory minimum if there is a minimum if there is a prior conviction of either prior conviction of either .7401 or .7403(2)(a), (b) .7401 or .7403(2)(a), (b) or (e);or (e);If serving a sentence If serving a sentence under the Felony Firearm under the Felony Firearm Law followed by an Law followed by an indeterminate sentence indeterminate sentence and has a minimum total and has a minimum total of 36 months or less, of 36 months or less, including the felony including the felony firearm;firearm;

Prisoner Reimbursement ActPrisoner Reimbursement Act

Prison Can Seek Reimbursement for Cost Prison Can Seek Reimbursement for Cost of Incarceration;of Incarceration;Prison is Looking for Inmate Assets to Prison is Looking for Inmate Assets to Seize and Sue to KeepSeize and Sue to Keep

Inmate completes an Offender Financial Inmate completes an Offender Financial Status Report Form at Intake (CFJStatus Report Form at Intake (CFJ--140);140);PSIPSI

Defending Prisoner Defending Prisoner Reimbursement Act SuitsReimbursement Act Suits

Many Defenses Have Been Eliminated by Many Defenses Have Been Eliminated by Court of Appeals and Supreme CourtCourt of Appeals and Supreme Court

Many Many ““Protected AssetsProtected Assets”” Can be Attached;Can be Attached;MDOC Will Settle for Cash on the Barrel.MDOC Will Settle for Cash on the Barrel.Further Information:Further Information:

If PLSM Has a Greater PrimerIf PLSM Has a Greater Primerfor About $10.for About $10.

Mich. Bar Journal Article: Mich. Bar Journal Article: Levy, Levy, 77 Mich. B.J. 19077 Mich. B.J. 190

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Inmate EmploymentInmate Employment

School, Work or Combination of Both;School, Work or Combination of Both;Special Security (public works and gate Special Security (public works and gate pass) Assignmentspass) AssignmentsMichigan State Industries (MSI)Michigan State Industries (MSI)StipendsStipends

““UnemployableUnemployable”” InmatesInmates

A Valid Medical Restriction A Valid Medical Restriction Segregation Segregation If Refuses to Accept or Actively participate If Refuses to Accept or Actively participate in work or school assignment;in work or school assignment;Refuses to Participate in Program Refuses to Participate in Program Classification;Classification;If there is a Documented History of If there is a Documented History of Disruptive Behavior on a work or school Disruptive Behavior on a work or school assignment.assignment.

Work and Program Work and Program Performance EvaluationsPerformance Evaluations

Important for Parole Consideration, Etc.Important for Parole Consideration, Etc.Performed Regularly:Performed Regularly:

School, Quarterly;School, Quarterly;Food Service, Monthly;Food Service, Monthly;Other Work, Initially followed by 6 Month Other Work, Initially followed by 6 Month EvaluationsEvaluations

Below Average Work Report Requires Below Average Work Report Requires Referral for ReclassificationReferral for Reclassification

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SegregationSegregation

Types of SegregationTypes of SegregationTemporary Segregation Temporary Segregation –– sometimes used if sometimes used if pending a hearing for a major misconduct pending a hearing for a major misconduct violation;violation;Protective or Administrative Segregation;Protective or Administrative Segregation;Punitive Segregation (Detention)Punitive Segregation (Detention)

Segregation and the LawSegregation and the Law

MDOC Granted Authority to Classify MDOC Granted Authority to Classify Individuals. MCL 791.264.Individuals. MCL 791.264.Generally, no Generally, no ““liberty interestliberty interest”” in in remaining out of segregation.remaining out of segregation.

SandinSandin v. Conner, 515 U.S. 472v. Conner, 515 U.S. 472(1995)(1995)..

Possible State Law Appeal. Possible State Law Appeal. Meadows v Warden, MBP, Meadows v Warden, MBP, 117 117 Mich.AppMich.App. 794 (1982).. 794 (1982).

Security ClassificationSecurity Classification

Inmate is Assigned a Level (I Inmate is Assigned a Level (I -- VI);VI);Interests and Needs of Inmates;Interests and Needs of Inmates;Management;Management;Control from Escape;Control from Escape;Inmates Can be Waived Up or Down Inmates Can be Waived Up or Down Based on Needs;Based on Needs;InmateInmate’’s True Level Effects Eligibility for s True Level Effects Eligibility for Many ProgramsMany Programs

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Prison Misconduct TicketsPrison Misconduct Tickets

Major v Minor TicketsMajor v Minor TicketsNo Right to CounselNo Right to CounselPreponderance of the EvidencePreponderance of the Evidence

Prison Misconduct HearingsPrison Misconduct Hearings

Debate Over Live TestimonyDebate Over Live TestimonyInternal Appeal AvailableInternal Appeal AvailableCan Be Appealed to Circuit Court Under Can Be Appealed to Circuit Court Under the Administrative Procedures Act. MCR the Administrative Procedures Act. MCR 7.105.7.105.

The Parole Eligibility (The Parole Eligibility (““PERPER””))

Initial Step for Parole Consideration; Initial Step for Parole Consideration; Prepared 8 Months Out;Prepared 8 Months Out;Supposed to receive Notice of Interview Supposed to receive Notice of Interview and Opportunity to Review Contents of and Opportunity to Review Contents of Counselor File;Counselor File;Report Contains Information pertaining to Report Contains Information pertaining to InmateInmate’’s s ““ActiveActive”” Offense(sOffense(s););The PER is heavily plagiarized from the The PER is heavily plagiarized from the PSI!PSI!

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Notice of IntentNotice of Intent

Three Months Prior to First Release Date;Three Months Prior to First Release Date;Notice Covers Issues Which the Parole Notice Covers Issues Which the Parole Board Intends to Consider;Board Intends to Consider;Notice if Often Very VagueNotice if Often Very Vague

Parole GuidelinesParole Guidelines

Parole Board Uses Guidelines Similar to Parole Board Uses Guidelines Similar to Sentencing Guidelines;Sentencing Guidelines;Crime and Offender History Guidelines are Crime and Offender History Guidelines are Usually Initially Drafted by Usually Initially Drafted by PrePre--sentencesentenceInvestigator;Investigator;MDOC Scoring Guide Available.MDOC Scoring Guide Available.

Guideline AppealsGuideline Appeals

Administrative Appeals Are Possible;Administrative Appeals Are Possible;Appeals Go to Scoring Unit in Lansing;Appeals Go to Scoring Unit in Lansing;The Board Rarely Agrees to Grant The Board Rarely Agrees to Grant Rehearing of a Flop Even Where Their Rehearing of a Flop Even Where Their Guideline Appeal Succeeds.Guideline Appeal Succeeds.

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Probabilities of ParoleProbabilities of Parole

Guidelines Have Three Probabilities for Guidelines Have Three Probabilities for Parole:Parole:

High. Presumptive entitlement to parole (+04 High. Presumptive entitlement to parole (+04 or higher);or higher);Average. No presumption of Parole (Average. No presumption of Parole (--03 or 03 or less, but greater than less, but greater than --13);13);Low. Presumption Low. Presumption against against parole (parole (--13 or 13 or less)less)

In Theory Departures Are Governed by In Theory Departures Are Governed by the Substantial and Compelling Standardthe Substantial and Compelling Standard

Sex Offender ParolesSex Offender Paroles

Interview Required Before Parole Granted;Interview Required Before Parole Granted;Exceptionally Difficult to Get Without Exceptionally Difficult to Get Without Completion of Therapy;Completion of Therapy;Admission of Guilt Needed for Therapy Admission of Guilt Needed for Therapy and Usually for Parole.and Usually for Parole.

Lifer ParolesLifer Paroles

Initial Interview 15 years;Initial Interview 15 years;Subsequent Interviews Discretionary With Subsequent Interviews Discretionary With the Board;the Board;File Review Every Five Years.File Review Every Five Years.

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Lifer Paroles ContinuedLifer Paroles Continued

Board Votes in Executive Session for Case Board Votes in Executive Session for Case to Proceed to Public Interview. to Proceed to Public Interview.

6 out of 10 votes for further proceedings 6 out of 10 votes for further proceedings required;required;

Case Then Sent to Judge and Prosecutor;Case Then Sent to Judge and Prosecutor;Judge Has Veto. Pros. Can Only Provide Judge Has Veto. Pros. Can Only Provide Input;Input;

Public Hearing Held.Public Hearing Held.

Inmate Input Into Parole ProcessInmate Input Into Parole Process

Parole Representative Permitted at Parole Representative Permitted at Interview;Interview;Inmate Can Submit Letters of Support, Inmate Can Submit Letters of Support, Documents Supporting Plan, etc.;Documents Supporting Plan, etc.;

Support Letters Should focus on support Support Letters Should focus on support provided;provided;Letters should be screened. Many of them Letters should be screened. Many of them actually hurt, (e.g. assert innocence, express actually hurt, (e.g. assert innocence, express political position not shared by PB, etc).political position not shared by PB, etc).

Victim Input Into the Parole Victim Input Into the Parole ProcessProcess

Victims Have Right to Notice of Parole Process;Victims Have Right to Notice of Parole Process;Right to Submit Opposition or Support for Right to Submit Opposition or Support for Parole. (This is Usually Kept Confidential from Parole. (This is Usually Kept Confidential from Prisoner);Prisoner);Right to a Meeting with a Parole Board Member Right to a Meeting with a Parole Board Member in Lansing.in Lansing.

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The Parole InterviewThe Parole Interview

Inmate, RUM (or Equivalent), Inmate, RUM (or Equivalent), Parole Representative, and Parole Representative, and Board Member;Board Member;Often Held by Video Link;Often Held by Video Link;One of Three votes is often One of Three votes is often cast before the interview is cast before the interview is held.held.

Role of RepresentativeRole of Representative

Board View is Representative is Board View is Representative is Not an Advocate;Not an Advocate;Reality Reality –– Laid Back Advocate;Laid Back Advocate;Family Members Should be Family Members Should be Briefed and Screened.Briefed and Screened.

Advocacy TipsAdvocacy Tips

NonNon--MDOC Parole Reentry Plan;MDOC Parole Reentry Plan;Think Real Hard Before Minimizing the Think Real Hard Before Minimizing the Offense; Offense; InmateInmate’’s hygiene and s hygiene and overall appearance is overall appearance is important. important.

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AppealsAppeals

Heads They Win; Tails They Lose;Heads They Win; Tails They Lose;Prisoner Appeals Eliminated in 1999;Prisoner Appeals Eliminated in 1999;Revised Judicature Back Door Slammed in Revised Judicature Back Door Slammed in Morales v. Michigan Parole Bd.Morales v. Michigan Parole Bd.,,260 260 Mich.AppMich.App. 29, 676 N.W.2d 221 . 29, 676 N.W.2d 221 (2003). (2003).

Alternate Litigation ApproachesAlternate Litigation Approaches

Federal Court Options Have Thus Far Federal Court Options Have Thus Far Failed. See Failed. See KosbarKosbar v Palmer, 2005 WL v Palmer, 2005 WL 2045819 (2045819 (W.D.MichW.D.Mich.) (collecting cases)..) (collecting cases).Mandamus Might be Available To Compel Mandamus Might be Available To Compel the Board to Comply with the Law;the Board to Comply with the Law;Habeas Corpus Not AvailableHabeas Corpus Not Available

WhatWhat’’s Left?s Left?

Beg!Beg!Board Does Entertain Requests for Board Does Entertain Requests for Reconsideration;Reconsideration;Rehearing is a Long ShotRehearing is a Long Shot

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Parole Reentry InitiativeParole Reentry Initiative

Intensive Parole Reentry Initiative;Intensive Parole Reentry Initiative;Eligibility Criteria;Eligibility Criteria;Placement;Placement;Parole Board May Parole Inmate Parole Board May Parole Inmate Contingent upon Successful Completion;Contingent upon Successful Completion;Program is 4 months;Program is 4 months;Parole Violators are Screened for Parole Violators are Screened for Eligibility.Eligibility.

Prosecution Parole AppealsProsecution Parole Appeals

Prosecutor or Victim Can Appeal by Leave Prosecutor or Victim Can Appeal by Leave GrantGrant of Parole under MCR 7.104(D);of Parole under MCR 7.104(D);Not an Equal Protection Violation;Not an Equal Protection Violation;Significant Body of Unpublished Significant Body of Unpublished Case Law in this AreaCase Law in this Area

Parole RescissionParole Rescission

Prior to Release, Parole Order may be Prior to Release, Parole Order may be Suspended; Reasons provided in Notice Suspended; Reasons provided in Notice of Action with Interview within 45 days;of Action with Interview within 45 days;After Release, Parole may be Rescinded After Release, Parole may be Rescinded but Must Have an Interview and Summary but Must Have an Interview and Summary of New Information that led to Interview.of New Information that led to Interview.Many Unresolved Legal Many Unresolved Legal Questions Regarding this Questions Regarding this Proceeding.Proceeding.

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Parole Placements TipsParole Placements Tips

Best to a Place Where the Inmate Has Best to a Place Where the Inmate Has Significant Ties;Significant Ties;Out of State Placements Take Longer. Out of State Placements Take Longer. Normally it is Better to Place to an Instate Normally it is Better to Place to an Instate Placement and Transfer.Placement and Transfer.

Exception: Sex Offenders;Exception: Sex Offenders;

Commercial Placement is the Placement of Commercial Placement is the Placement of Last Resort.Last Resort.

Conditions/SupervisionConditions/Supervision

Take Parole Under Any Circumstances;Take Parole Under Any Circumstances;Conditions Can be Changed;Conditions Can be Changed;Think About the County You Place To;Think About the County You Place To;An Agent Can Tack on Temporary Parole An Agent Can Tack on Temporary Parole Conditions Subject to Board Conditions Subject to Board Approval/Veto;Approval/Veto;

Parole RevocationParole Revocation

Not All Violations of Parole Conditions Not All Violations of Parole Conditions Result in Revocation;Result in Revocation;Revocation Started by Agent, Approved by Revocation Started by Agent, Approved by Supervisor;Supervisor;Pressure on Division Heads Not to Revoke.Pressure on Division Heads Not to Revoke.

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Alternatives to Prison ReturnAlternatives to Prison Return

Parole Violator Diversion (PVD) Program Parole Violator Diversion (PVD) Program Technical Rule Violator (TRV) ProgramTechnical Rule Violator (TRV) ProgramUsually Offered to Inmate Prior to Usually Offered to Inmate Prior to Commencement of Formal Parole Commencement of Formal Parole Revocation.Revocation.

Revocation ArraignmentRevocation Arraignment

PV Charges are presented; PV Charges are presented; Parolee may request a Preliminary Parolee may request a Preliminary Violation Hearing.Violation Hearing.

Preliminary Parole Violation Preliminary Parole Violation HearingHearing

Counsel Only Permitted in Special Counsel Only Permitted in Special Circumstances (Rarely Found);Circumstances (Rarely Found);Parolee is given at least 48 hours written Parolee is given at least 48 hours written notice of the time, date and location of notice of the time, date and location of the Preliminary Parole Violation Hearing;the Preliminary Parole Violation Hearing;When To Ask for a Different Hearing When To Ask for a Different Hearing Examiner.Examiner.

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Revocation Final HearingRevocation Final Hearing

Attorneys Permitted/AppointedAttorneys Permitted/AppointedDiscovery (Informal)Discovery (Informal)

Board Denies Authority to Issue Subpoenas;Board Denies Authority to Issue Subpoenas;

CrossCross--Examination;Examination;Rules of Evidence Kind of Rules of Evidence Kind of –– Sort of Sort of ––Apply.Apply.

Revocation Revocation –– Lansing ReviewLansing Review

The Final Decision regarding Revocation of The Final Decision regarding Revocation of Parole is made by the Parole Board in Parole is made by the Parole Board in accordance with Administrative Rule accordance with Administrative Rule 791.7765791.7765Written Findings and Reasons for Written Findings and Reasons for Revocation are to be Provided within 60 Revocation are to be Provided within 60 days after Returndays after Return

Revocation Revocation –– RehearingRehearing

Board Entertains Request for Rehearing;Board Entertains Request for Rehearing;Open Debate Whether this Tolls Time for Open Debate Whether this Tolls Time for Circuit Appeal. Circuit Appeal. Utilize MCR 2.119(f) standards by analogy.Utilize MCR 2.119(f) standards by analogy.

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Revocation AppealsRevocation Appeals

AppealableAppealable Under APA to Circuit Court;Under APA to Circuit Court;60 Days from Date of Decision60 Days from Date of DecisionInmates County of Residence or Ingham Inmates County of Residence or Ingham CountyCountyGoverned by MCR 7.105Governed by MCR 7.105

Parole DischargeParole Discharge

Parole Discharge Date Does Not Create a Parole Discharge Date Does Not Create a Liberty Interest. Liberty Interest. Terms of Parole Can be Extended Up to Terms of Parole Can be Extended Up to the Last Daythe Last DayDischarges Are Not Binding Until Discharges Are Not Binding Until Delivered.Delivered.

Small Possibility that they Can be Small Possibility that they Can be Retroactively Revoked. Retroactively Revoked. People v. Young, People v. Young, 220 220 Mich.AppMich.App. 420 (1996).. 420 (1996).

Questions?Questions?Stuart G. FriedmanAttorney at Law843 Penniman AvenueaPlymouth, MI 48170(734) 662-4070stu@crimapp.com

Kathleen SchaeferParole & Probation Consulting2632 Buhl BuildingDetroit, MI 48226(313) 882-6178schaefkm@comcast.net