Due process; Prearrest delay; People v Woolfolk; 180-day rule trigger; MCL 780.131; People v Lown

The court held that the trial court did not abuse its discretion by denying dismissal because the defendant failed to show actual prejudice from any prearrest delay and the statutory detainer timelines were never properly triggered. The record showed an armed robbery investigated through surveillance video, phone records, and social media identification, followed by a delayed arraignment while the defendant was in federal custody. On appeal, the court rejected the prearrest-delay claim because defendant did not prove “actual and substantial prejudice, not mere speculation,” and the supposedly missing witness in fact testified at trial without any shown impairment. The court also held the 180-day rule did not apply because the statute requires certified-mail notice to the prosecuting attorney, and “the 180-day rule was never triggered” where notice went elsewhere.