See also People v Givans, 227 Mich App 113, 125-126; 575 NW2d 84 (1997) (holding that a defendant was not entitled to a jail credit toward his sentence for a conviction in Jackson County from his incarceration for a separate Washtenaw County conviction, as "MCL 769.11b . . . provides that a defendant shall receive credit for the time he has served before sentencing for the offense of which he is convicted."); People v McKnight, 165 Mich App 66, 68-69; 418 NW2d 402 (1987) (applying Prieskorn, 424 Mich at 340). --------

This Court, in several cases that followed, held that time spent in jail on unrelated charges does not qualify for sentence credit, see, e.g., People v Ovalle, 222 Mich App 463; 564 NW2d 147 (1997), even if those unrelated charges are dismissed as part of a plea bargain in the case for which the defendant later seeks credit. People v McKnight, 165 Mich App 66; 418 NW2d 402 (1987). Here, defendant was arrested on the charge for which he pleaded guilty on July 27, 2011.

11b; People v. Prieskorn, 424 Mich. 327, 344, 381 N.W.2d 646 (1985); and Petitioner seeks credit for the time served on the resisting and obstructing a police officer charge which was unrelated to his first-degree retail fraud case. That Petitioner pleaded guilty to the resisting and obstructing charge as part of the same plea bargain in which he pleaded guilty to the first-degree retail fraud charge does not change the result because the offenses were unrelated. See People v. McKnight, 165 Mich. App. 66, 68-70, 418 N.W.2d 402 (1987). Because Michigan law does not create a right to the sentencing credit that Petitioner seeks, his claim is not cognizable on habeas review.