State v. Lewis, 184 Wash. 2d 201

Adam Lewis was arrested May 13, 2011, on burglary and assault charges; remained jailed pretrial because he could not make bail.
While awaiting trial on those charges, prosecutor charged him with failure to register as a sex offender; for 387 days he was confined awaiting trial on all three matters.
Lewis pleaded guilty to failure to register on Aug 31, 2012, was sentenced to 50 months and given credit for the 387 days; he began serving that sentence immediately.
Lewis later pleaded guilty to burglary (Oct 26, 2012) and assault (Nov 5, 2012); at sentencing on those counts (Dec 14, 2012) the trial court credited him for all time served from his May 13, 2011 arrest through sentencing (including the 387 days and 105 days served after beginning the sex‑offender sentence) and ordered concurrent sentences.
The State appealed; the Court of Appeals reversed credit for the 387 days (double‑credit concern) and for the 105 days after Lewis began serving the sex‑offender sentence.
On review the State conceded Lewis is entitled to credit for the 387 days; the Supreme Court accepted that concession, affirmed that Lewis is not entitled to credit for time served after he began serving another sentence, and remanded for resentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Lewis is entitled to credit for 387 days of pretrial confinement spent awaiting multiple pending charges	Lewis: equal protection/due process entitle him to credit on assault/burglary for time confined pretrial on all charges	State: credit denied would avoid double‑counting and follow statutory language limiting credit to confinement "solely" for the offense sentenced	Court accepted State concession: Lewis gets 387 days credit on assault/burglary to avoid disparity between those who can make bail and those who cannot (Reanier rule)
Whether Lewis is entitled to credit for the 105 days after Aug 31, 2012 when he was serving a sentence for failure to register	Lewis: still entitled to credit on burglary/assault because confinement continues to restrict liberty	State: incarceration after Aug 31 was confinement resulting from a sentence, not pretrial detention; no equal protection problem if sentenced confinement counts only toward the sentence being served	Held for State: no constitutional right to credit after he began serving a separate sentence; Court of Appeals properly denied that credit

In re Habeas Corpus of Reanier, 83 Wn.2d 342 (1974) (pretrial detainee unable to make bail cannot be made to serve more confinement than a detainee who made bail)
State v. Alejandro Medina, 180 Wn.2d 282 (2014) (distinguishing confinement due to sentence from pretrial detention for credit purposes)
State v. Lewis, 185 Wn. App. 338 (2014) (Court of Appeals decision reversing trial court credit; discussed double‑credit and post‑sentence confinement)