In People v. Wills (1994) 22 Cal.App.4th 1810, the defendant received probation for a drug offense, but later was sent to prison for violating the terms of his probation. The defendant appealed, claiming the trial court failed to award him conduct credits under section 4019 for the time he spent in a county work release program under section 4024.2. Although by its terms section 4019 applies only when "a prisoner is confined in or committed to a county or city jail, industrial farm, or road camp" ( 4019, subd. (a)), and the defendant "lived at his girlfriend's home and worked at a senior citizen's center" while on work release, the defendant argued he nonetheless was entitled to conduct credits because section 4024.2 provides that each day of participation in a work release program is " 'in lieu of one day of confinement.' " (Wills, at p. 1812.) In other words, the defendant asserted that if days participating in work release are deemed "in lieu of" confinement for purposes of section 4024.2, then the same understanding must apply for determining whether the defendant should receive credit for those days under section 4019. The Wills court rejected the argument on the ground that section 4019, subdivision (f), "makes it clear the Legislature did not intend to make available conduct and work time credits unless the probationer is 'in actual custody." (Wills, supra, 22 Cal.App.4th at p. 1813.) Moreover, the court held that a work release participant is not "in actual custody" for purposes of section 4019 as a matter of law, based on the provision in section 4024.2 authorizing a peace officer to " 'retake the person into custody ... to complete the remainder of the original sentence' " in the event the "participant fails to appear for work or even fails to work as assigned." (Wills, at p. 1813.) In light of that provision, the court observed that "no possible reading of section 4024.2 would support the conclusion" a work release participant "is in actual custody for the purpose of section 4019 conduct and work credits." (Wills, supra, at p. 1813.)