State of Idaho, Plaintiff-Respondent v. Dameniel Preston Owens, Defendant-Appellant

Summary

The Idaho Supreme Court held that Idaho Code section 18-309 requires prejudgment incarceration credit for each offense underlying the incarceration, including offenses carrying consecutive sentences. It overruled State v. Hoch because that decision relied on assumed legislative intent rather than the statute's unambiguous plain language, vacated the district court's order, and remanded. The Court also held that its new interpretation applies prospectively and on direct review, but not retroactively to cases on collateral review.