San Miguel, State v. Prevost

In San Miguel, State v. Prevost, 118 Ariz. 100, 574 P.2d 1319 (App. 1977), the Court determined a defendant was not entitled to credit for time spent incarcerated for a federal offense before the state trial court revoked his release based on the federal arrest. Id. at 102-03, 574 P.2d at 1321-22. The Court determined, however, that he could be entitled to presentence credit for time spent in custody after his release had been revoked because he had been "confined for both the state and federal charges." Id. at 103-04, 574 P.2d at 1322-23.