State v. Lance Tyrell Taylor, 373 P.3d 699

Taylor pleaded guilty to grand theft in January 2013; the court suspended a 10-year sentence and placed him on ten years’ probation beginning March 26, 2013, requiring successful enrollment and completion of Ada County Drug Court.
Taylor entered drug court March 27, 2013, and was intermittently incarcerated during the program for sanctions and after absconding; he remained in custody from his February 26, 2014 arrest until resentencing on June 12, 2014.
The district court credited 292 days of pre-judgment custody but denied credit for some jail time served while Taylor participated in drug court, treating that incarceration as sanctions or discretionary probation conditions.
Taylor filed motions seeking additional credit for multiple incarceration periods; the district court awarded credit for periods it characterized as pre-sentence, post-arrest (bench-warrant), and post-violation custody, but denied credit for incarceration occurring as drug-court sanctions.
On appeal Taylor argued (1) that 2015 amendments to Idaho’s credit statutes should be applied retroactively to award him credit, and (2) alternatively that under the pre-amendment statutes and his written probation terms he did not agree to discretionary jail time, so drug-court jail time must be credited against his sentence.

Issue	Taylor's Argument	State's Argument	Held
Are 2015 amendments to Idaho’s credit statutes retroactive?	Amendments should be applied retroactively to give credit for drug-court custody.	Amendments are not retroactive.	Not retroactive; pre-amendment law governs.
Is incarceration during drug court creditable against sentence under pre-amendment law?	Time in jail while in drug court is pre-judgment/incarceration attributable to the offense and must be credited; he did not voluntarily agree to discretionary jail as a probation condition.	Time served as drug-court sanctions is discretionary/condition of probation and not creditable.	Reversed district court: drug-court incarceration is creditable.
Did Taylor’s written probation order authorize discretionary jail time as a condition of probation?	Probation terms did not include mandatory discretionary incarceration; condition expressly preserved credit for time not imposed as condition of probation.	Drug-court participation implicitly allowed sanctions including jail.	Probation order did not authorize incarceration as a condition; thus custody must be credited.
Remedy / next step	Award credit and determine total days to apply against sentence.	If some periods are discretionary, no credit for those.	Affirmed credit for other periods; reversed denial for drug-court period; remand to calculate total days.

State v. Buys, 129 Idaho 122, 922 P.2d 419 (interpreting when probation-ordered jail is voluntary and not creditable)
State v. Banks, 121 Idaho 608, 826 P.2d 1320 (defendant may decline probation terms; probation conditions control credit analysis)
State v. Dunlap, 155 Idaho 345, 313 P.3d 1 (statutory interpretation principles)
State v. Owens, 158 Idaho 1, 343 P.3d 30 (statutory interpretation; review standards)
State v. Vasquez, 142 Idaho 67, 122 P.3d 1167 (credit-for-time-served is reviewed as a question of law)