State v. Pannell, 267 P.3d 349

Pannell pled guilty to incest and child molestation; sentence suspended under SSOSA pending satisfactory treatment progress.
He began outpatient sexual offender treatment but failed to make satisfactory progress.
The suspended sentence was revoked and the court imposed the full 116-month term plus 3–4 years of postrelease community placement.
Pannell sought credit against the maximum 120 months for time spent in the community under the suspended SSOSA.
The trial court and Court of Appeals held time in the SSOSA community during suspension is not creditable toward the maximum.
The Supreme Court held no credit for pre-revocation SSOSA community time, affirming the Court of Appeals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether SSOSA time in the community pre-revocation is creditable against the statutory maximum.	Pannell argues time in the community under SSOSA should be credited.	State argues SSOSA time is not creditable toward the maximum.	No credit for pre-revocation SSOSA community time.
Whether RCW 9.94A.670 and related statutes require credit for time spent in SSOSA community custody.	Pannell relies on community custody counted as part of sentence.	State reads statutes to treat SSOSA time separately from maximum confinement.	SSOSA time spent in the community is not credited toward the maximum.
Whether postrevocation postconfinement community custody can be credited toward the maximum after revocation.	Pannell contends combined time could exceed max if credited.	Legislature intended no such cross-credit.	No credit against maximum for pre-revocation SSOSA community time.

Brooks v. State, 166 Wn.2d 664 (2009) (credit rules for confinement versus community custody under SR Act)
Miller v. State, 159 Wn. App. 911 (2011) (SSOSA credit distinctions and post-release custody)
Gartrell v. State, 138 Wn. App. 787 (2007) (SSOSA time not credited toward postconfinement custody)