State v. Osborn, 449 P.3d 419

Christopher Osborn pleaded guilty to two separate misdemeanor violations of a no-contact order and received two consecutive 365‑day jail sentences; both were suspended and he was placed on two concurrent two‑year probations.
Osborn absconded; the State obtained a bench warrant and later arrested him on new criminal charges and served the outstanding bench warrant for the probation violations related to both suspended sentences.
Osborn remained in custody 106 days after service of the bench warrant before admitting the probation violations.
The magistrate court revoked probation, imposed the original consecutive sentences, and credited Osborn with 106 days—but only against the first of the two consecutive sentences.
Osborn sought Rule 35 relief to receive the 106 days credit on both counts; the magistrate denied relief, the district court reversed and awarded credit on both counts, and the State appealed to the Idaho Supreme Court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether I.C. § 19‑2603 entitles a defendant to credit for time served on each suspended sentence when a bench warrant for probation violations covers multiple offenses and the sentences are consecutive	The State: credit for time served need only be applied once against the structured (consecutive) sentence; the defendant began serving the first sentence at arrest and was given full credit	Osborn: § 19‑2603 requires credit for time served against each suspended sentence for which the bench warrant applied	Court affirmed district court: credit for time served must be granted against each suspended sentence when the bench warrant applies to multiple offenses (Osborn credited 106 days on each count)
When does execution of a suspended sentence begin for credit purposes under I.C. § 20‑222(2) and § 19‑2603?	The State: arrest/rearrest effectively began service of the suspended sentence, so single credit suffices	Osborn/district court: a suspended sentence is not executed until the court revokes probation; credit accrues for time served after bench‑warrant service and applies to each suspended sentence	Court held that sentence execution occurs on revocation; time served from service of the bench warrant is credited under § 19‑2603 and must be applied to each suspended sentence covered by the warrant

State v. Owens, 158 Idaho 1 (2015) (discussed credit‑for‑time‑served principles and statutory scope)
State v. Schulz, 151 Idaho 863 (2011) (statutory interpretation: start with plain language)
State v. Dunlap, 155 Idaho 345 (2013) (give words their ordinary meaning; treat statute as whole)
Verska v. Saint Alphonsus Reg’l Med. Ctr., 151 Idaho 889 (2011) (courts should not revise unambiguous statutes)
Sturges v. Crowninshield, 17 U.S. (1819) (historic exposition of avoiding only truly monstrous absurdities in statutory construction)
The David & Marvel Benton Tr. v. McCarty, 161 Idaho 145 (2016) (refusal to adopt absurd readings of unambiguous statutes)
State v. Easley, 156 Idaho 214 (2014) (separation‑of‑powers limits on prosecutorial influence over sentencing)