State v. Rocha
In State v. Rocha, 117 Ariz. 294, 572 P.2d 122 (App. 1977), the defendant was allowed to remain free on bond pending appeal.
While his appeal was pending, the defendant committed and was convicted of a federal narcotics offense for which he was incarcerated.
After his state court conviction was affirmed, the trial court ordered partial forfeiture of the cash bond posted by defendant even though he was unable to surrender to state authorities because he was still in federal custody.
In rejecting defendant's claim that the partial forfeiture of his cash bond should be set aside as unduly harsh, we noted that defendant's "detention by the federal authorities was because of his own misconduct and is not excusable." Id. at 297, 572 P.2d at 125.