State v. Jason Roy Barrett, 414 P.3d 1188

Barrett was incarcerated on a prior unrelated conviction when the State obtained an arrest warrant (June 8, 2015) for new drug- and paraphernalia-related charges.
On July 24, 2015 an Ada County "Hold Notice Request" (detainer) was emailed to IDOC and served on Barrett in prison; Barrett and a DOC officer signed it.
The arrest warrant for the new charges was not served on Barrett until his initial appearance on September 9, 2015.
Barrett pleaded guilty to a felony; sentencing was imposed to run concurrent with his prior sentence. He sought credit for time served beginning when the Hold Notice Request was served (July 24), an additional 47 days beyond the district court's credit beginning September 9.
The Court of Appeals awarded the additional 47 days; the Idaho Supreme Court granted review and affirmed the district court, holding the Hold Notice Request did not provide a legal basis for incarceration under I.C. § 18-309.

Issue	Barrett's Argument	State's Argument	Held
Whether a non-judicial Hold Notice Request served on an incarcerated defendant can satisfy the "arrest warrant"/basis-for-incarceration requirement of I.C. § 18-309 so as to earn credit for pre-judgment incarceration	The Hold Notice Request functioned as a de facto basis for incarceration so Barrett was held for the new charges from service of the hold and is entitled to credit from that date	Under Brand, incarceration for the new offenses did not begin until the arrest warrant was served at initial appearance; the Hold Notice Request lacked legal authority to incarcerate	The Hold Notice Request did not legally or actually incarcerate Barrett such that § 18-309 applied; credit does not begin until the arrest warrant was served

State v. Brand, 162 Idaho 189 (2017) (articulates two-part test for pre-judgment credit when defendant was already jailed for unrelated offense)
State v. Owens, 158 Idaho 1 (2015) (§ 18-309 requires credit for pre-judgment incarceration for offenses resulting in conviction)
State v. Taylor, 160 Idaho 381 (2015) (question of proper award of credit for time served is reviewed as a question of law)
State v. Garcia-Rodriguez, 162 Idaho 271 (2017) (Supreme Court reviews Court of Appeals decisions directly when granting review)