State v. Brand & Nall, 395 P.3d 809

Brand and Nall were already incarcerated on unrelated charges when served with Idaho arrest warrants for additional state offenses.
Brand: served with a grand-theft warrant while jailed on a drug-possession charge; later pled guilty and was given 4 days’ credit by the district court; sought credit for 190 days from warrant service to judgment.
Nall: in federal custody on a no-bond hold when served with state warrants; pled guilty to state charges; district court initially noted conditional credit but later—after federal credit was confirmed—reduced state credit to zero; Nall appealed.
Both district courts denied the requested additional prejudgment credit on the ground that the defendants’ custody was imposed for unrelated prior offenses, so the new state charges did not affect their liberty.
The Idaho Supreme Court granted review and considered whether Idaho Code § 18-309 requires credit for prejudgment incarceration when the detention was initiated and maintained by unrelated prior charges.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 18-309 authorizes credit for prejudgment incarceration when defendant was already jailed for unrelated charges	Brand/Nall: § 18-309 mandates credit for any prejudgment incarceration ‘‘for the offense’’—credit applies so long as the incarceration was for the offense sentenced, even if custody was initiated/maintained by other charges	State: No credit where the pending state proceeding had no effect on defendant’s liberty because they were already confined for unrelated charges	Held: Reversed. § 18-309’s plain language entitles defendants to credit if (1) they were incarcerated during the period from service of the warrant to judgment, and (2) the offense for which credit is sought provides a basis for the defendant’s incarceration; unrelated prior custody does not bar credit.

State v. Owens, 158 Idaho 1, 343 P.3d 30 (2015) (§ 18-309 plainly gives credit for prejudgment custody against each count’s sentence)
Pocatello v. State, 145 Idaho 497, 180 P.3d 1048 (statutory interpretation is a question of law reviewed de novo)
State v. Burnight, 132 Idaho 654, 978 P.2d 214 (plain-language statutory construction)
State v. Schall, 157 Idaho 488, 337 P.3d 647 (appellate review principles for Supreme Court review)
State v. Oliver, 144 Idaho 722, 170 P.3d 387 (same)
State v. Horn, 124 Idaho 849, 865 P.2d 176 (credit only for presentence incarceration attributable to the offense)
State v. Moore, 156 Idaho 17, 319 P.3d 501 (defendant entitled to credit for time actually served prior to judgment)
State v. Vasquez, 142 Idaho 67, 122 P.3d 1167 (credit limited to incarceration caused by the offense)
State v. Rodriguez, 119 Idaho 895, 811 P.2d 505 (similar principle)
State v. Hale, 116 Idaho 763, 779 P.2d 438 (similar principle)
State v. Dorr, 120 Idaho 441, 816 P.2d 998 (no credit when pending proceeding has no effect on defendant’s liberty)
State v. Moliga, 113 Idaho 672, 747 P.2d 81 (same)
State v. Hernandez, 120 Idaho 785, 820 P.2d 380 (statutory limits on credit for prejudgment confinement)