State v. San Miguel
In State v. San Miguel, 132 Ariz. 57, 643 P.2d 1027 (App. 1982), a defendant was arrested for a charged offense and a probation revocation based on that offense. Id. at 58, 643 P.2d at 1028.
He was released on his own recognizance on the new offense but held without bond on the probation violation. Id.
The Court determined on appeal that he was not entitled to presentence credit on his sentence for the new offense because he had not been confined due to that charge, but instead "as a result of the petition to revoke" his probation. Id. at 61, 643 P.2d at 1031.