In re Jabari C., 2011 IL App (4th) 100295

Open guilty plea to amended charge unlawful possession with intent to deliver cannabis on school grounds (Class A misdemeanor).
Sentencing on March 18, 2010: indeterminate Department of Juvenile Justice term terminates after 364 days or at age 21, with 17 days time spent in custody credited.
May 1, 2009 arrest at school; 1.7 grams cannabis found; not admitted to detention center that date.
May 14, 2009 formal station adjustment; adjustment later terminated due to a subsequent violation.
June 17, 2009 petition filed; March 18, 2010 adjudication and sentencing; issue on additional day of credit for May 1 arrest arises on appeal.
Court remanded with directions to amend sentencing order to reflect one additional day of sentencing credit against the sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether respondent is entitled to one additional day of sentence credit for the May 1, 2009 arrest	People argues no credit for May 1 arrest	Jabari argues he is entitled to predetention credit for the May 1 arrest	Yes; entitled to one additional day of credit
Whether predetention custody during the station adjustment counts toward sentencing credit	People contends station adjustment time not custody for credit	Jabari contends custody includes time spent before sentencing	Yes; time in custody before sentencing counts for credit
Whether the appeal is moot	People contends appeal remains live due to potential parole consequences	Jabari argues mootness	Not moot; appeal remains capable of relief

In re J.T., 221 Ill. 2d 338 (2006) (juvenile predisposition credit for indeterminate term affirmed)
People v. Beachem, 229 Ill. 2d 237 (2008) (definition of custody for sentencing credit includes legal duty to submit to authority)
In re Rakim V., 398 Ill. App. 3d 1057 (2010) (predisposition credit for time incarcerated; applies to juveniles)
In re Jesus R., 326 Ill. App. 3d 1070 (2002) (deny juvenile credit could exceed adult maximum; trend toward equality with adults)