State v. Dameniel Preston Owens, 158 Idaho 1

Owens pled guilty to eight counts of issuing a check without funds; sentenced to unified terms of 15 months with six months fixed on each count; the eight counts were ordered consecutively.
The district court awarded prejudgment jail credit on only one of the eight counts; Owens moved to have the same prejudgment credit applied to each count.
Owens acknowledged controlling precedent (State v. Hoch) but urged the court to overrule it as inconsistent with the plain language of Idaho Code § 18-309.
The Idaho Supreme Court reviewed statutory interpretation de novo and considered whether Hoch was "manifestly wrong" such that stare decisis should be overturned.
The Court held § 18-309 unambiguous and requiring prejudgment credit be applied to each sentenced offense, overruled Hoch, vacated the district court order, and remanded.
The Court declined to apply its new interpretation retroactively on collateral review under Teague; the new rule was prospective and applied to cases on direct review only.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Idaho Code § 18-309 requires prejudgment jail credit on each sentence/count	Owens: § 18-309 is plain and unambiguous; a defendant "shall receive credit" for prejudgment incarceration for the offense, so credit applies to each sentenced offense	State: Allowing credit on each count would multiply time credited beyond actual days served; Hoch correctly prevents "pyramiding" of credit	Court: § 18-309 is unambiguous; credit applies to each offense/sentence; Hoch was wrongly decided and is overruled
Whether the new interpretation applies retroactively on collateral review	Owens implicitly seeks credit for past cases under new rule	State: New rule should not apply retroactively; finality concerns	Court: The decision announces a new rule under Teague and is not retroactive on collateral review; it applies prospectively and to cases on direct review

State v. Hoch, 102 Idaho 351 (1981) (prior Idaho precedent disallowing multiple prejudgment credits for consecutive sentences; overruled)
Law v. Rasmussen, 104 Idaho 455 (1983) (statutory credit for prejudgment time served under § 18-309)
Teague v. Lane, 489 U.S. 288 (1989) (framework for retroactivity of new criminal rules on collateral review)
Rhoades v. State, 149 Idaho 130 (2010) (adoption of Teague test for retroactivity in Idaho)
State v. Lawrence, 98 Idaho 399 (1977) (discussion of common-law sentencing authority and treatment of consecutive terms)