State v. Mahler
In State v. Mahler, 128 Ariz. 429, 430, 626 P.2d 593, 594 (1981) the Arizona Supreme Court granted a defendant credit for time served in Nevada pursuant to his Arizona offense.
The court reasoned that as a matter of plain language, the presentence credit statute2 referred to "all time" spent in custody pursuant to an Arizona offense, making no distinction between custody in Arizona or in another jurisdiction. Id.
However, the Court later clarified that presentence incarceration credit is unavailable for time served based on a charge other than that for which the defendant is being sentenced, because such incarceration is not "pursuant to" the relevant offense. State v. Horrisberger, 133 Ariz. 569, 570, 653 P.2d 26, 27 (App. 1982).