State v. William R. Joe(077034), 155 A.3d 563

In 2010 William R. Joe was charged in New Jersey with narcotics offenses, fled, and a bench warrant issued; he was later arrested in New York on unrelated weapons charges and remained in New York custody through sentencing.
Warren County prosecutors lodged an interstate detainer with New York on August 12, 2011; Joe was not transferred to New Jersey until after his New York sentence was resolved.
Joe pleaded guilty in New Jersey in 2013 and sought 236 days of jail credit under Rule 3:21-8 for time spent in pre-sentence custody in New York. The trial court denied credit.
The Appellate Division awarded credit from the date the detainer was lodged until the New York sentencing, relying on State v. Hernandez. The State sought and obtained certification by the New Jersey Supreme Court.
The Supreme Court reversed the Appellate Division and reinstated the trial court sentence, holding that out-of-state pre-sentence confinement on non-New Jersey charges does not entitle a defendant to Rule 3:21-8 jail credit unless the confinement was due solely to New Jersey charges.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Joe)	Held
Whether time a defendant spends in out-of-state pre-sentence custody on non-New Jersey charges must be credited under Rule 3:21-8	Hernandez should not apply when confinement is not solely due to NJ charges; New Jersey lacked control over out-of-state custody so no risk of double punishment or prosecutorial manipulation	Rule 3:21-8 (as interpreted in Hernandez) requires credit for any pre-sentence custody time regardless of where it was served	Court held no; jail credit under Rule 3:21-8 is not available for time spent in out-of-state pre-sentence custody when confinement arises from non-New Jersey charges unless confinement was solely for NJ charges

State v. Hernandez, 208 N.J. 24 (2011) (interpreted Rule 3:21-8 to maximize jail-credit effect across aggregate sentences and parole ineligibility to advance fairness and uniformity)
State v. Carreker, 172 N.J. 100 (2002) (denied gap-time credit for out-of-state incarceration and emphasized IAD protections and uniformity concerns)
State v. Rawls, 219 N.J. 185 (2014) (described jail credits as mandatory day-for-day credits under Rule 3:21-8)
State v. Black, 153 N.J. 438 (1998) (prior attribution rule: credit only for confinement attributable to the particular offense)
State v. Hemphill, 391 N.J. Super. 67 (App. Div.) (2007) (credited out-of-state incarceration when defendant was held exclusively on a New Jersey warrant)
State v. Beatty, 128 N.J. Super. 488 (App. Div. 1974) (credited out-of-state custody where detention was solely due to New Jersey detainer)
State v. Council, 137 N.J. Super. 306 (App. Div. 1975) (denied credit where defendant was confined for unrelated federal charges and New Jersey detainer did not extend confinement)