Walker-Bey v. Dep't of Corrections

In Walker-Bey v. Dep't of Corrections, 222 Mich App 605; 564 NW2d 171 (1997), the Court construed MCR 2.107(G) in light of a sixty-day filing deadline for prisoner appeals in contested cases, MCL 791.255; MSA 28.2320(55)(2). The Court rejected the "prisoner mailbox rule," which would count the day a prisoner hands the document to prison officials as the day of filing, reasoning that MCR 2.107(G) "unambiguously" required delivering the document to the court clerk or the judge within the statutory period. Id. at 609. Thus, Walker-Bey suggests that a document must actually reach the court clerk or the trial judge in order to be "filed."