State v. Jason Roy Barrett, 43947

Barrett was arrested May 15, 2015 for a parole violation and found in possession of marijuana and methamphetamine; an arrest warrant for the new possession/delivery charge issued June 8, 2015.
While already incarcerated on the parole violation, Barrett was served with a Hold Notice Request (described as a detainer/hold) on July 24, 2015 and later served with the arrest warrant for the new charge on September 9, 2015.
Barrett pled guilty to possession of a controlled substance with intent to deliver and was sentenced January 21, 2016 to ten years (3.5 years determinate), concurrent with his prior sentence.
The district court awarded credit for 135 days (from service of the arrest warrant to judgment) but denied credit for the 47 days between the Hold Notice Request (July 24) and the arrest warrant (September 9).
Barrett appealed, arguing (1) his sentence was excessive and (2) he was entitled to credit for the period beginning with the Hold Notice Request because it effectively incarcerated him for the charged offense.

Issue	Barrett's Argument	State's Argument	Held
Sentencing abuse — excessive sentence	Sentence failed to weigh mitigating factors (addiction, depression, remorse, family support); sentence unreasonable	Sentence appropriate given criminal history, public-safety concerns, and low rehabilitation prospects	Court affirmed: no abuse of discretion; sentence reasonable and grounded in deterrence and protection of public
Credit for prejudgment incarceration — whether hold notice triggers credit under I.C. § 18-309	Hold Notice Request effectively put Barrett "for the offense" and actually operated to incarcerate him, so he is entitled to credit from its service	Hold notice is merely notice of future arrest and lacks the legal effect of an arrest warrant; credit should begin at arrest-warrant service	Court reversed: applying Brand, credit is required when a defendant is actually or legally held for the offense; Barrett made sufficient showing that the hold had actual incarceratory effect, so he is entitled to credit from the hold’s service to the arrest-warrant service

State v. Brand, 162 Idaho 189 (Idaho 2017) (two-prong rule: defendant incarcerated after service of arrest warrant and the offense provides a basis for incarceration mandates credit)
State v. Owens, 158 Idaho 1 (Idaho 2015) (I.C. § 18-309 permits accrual of credit for multiple offenses simultaneously)
State v. Moore, 156 Idaho 17 (Ct. App. 2014) (I.C. § 18-309 is mandatory; defendant entitled to credit for all time actually incarcerated before judgment)
State v. Covert, 143 Idaho 169 (Ct. App. 2006) (discussing functional equivalence of warrants/detainers in credit-for-time-served context)
State v. Bitkoff, 157 Idaho 410 (Ct. App. 2014) (discussion of detainers/holds under the Interstate Agreement on Detainers and their purpose)