Anchorage v. Bussell
In Anchorage v. Bussell, 702 P. 2d 667 (Alaska App. 1985), the Court held that the defendant could not receive credit toward his sentence for time he had spent in treatment before reporting to jail because the court had never issued a valid order mandating that treatment.
The Court observed that time voluntarily spent in a restrictive treatment environment does not automatically entitle a defendant to credit for time served.
In Bussell, the defendant voluntarily entered a residential treatment program after receiving assurances from the trial court that he would be given credit against his sentence for the time he spent there.