context: Most state courts that have decided this question have applied a similar rule under their presentence credit statutes.
citation_a.signal: see
citation_a.identifier: 473 N.Y.S.2d 479, 480
citation_a.parenthetical: where defendant seeks sentence credit for jail time spent in another jurisdiction, he must demonstrate that the custody resulted solely from a New York detainer
citation_a.sentence: See State v. Horrisberger, 133 Ariz. 569, 570, 653 P.2d 26, 27 (Ct. App. 1982) (where defendant was in custody of other states on charges brought in those states, “holds” placed by Arizona were irrelevant under sentence credit statute because defendant was never able to satisfy conditions of release imposed by other states); State v. Akbar, 419 N.W.2d 648, 650 (Minn. Ct. App. 1988) (sentence credit is not allowed for time spent in out-of-state incarceration unless such incarceration is solely in connection with the Minne sota offense) (citing State v. Brown, 348 N.W.2d 743, 748 (Minn. 1984)); Keffer v. Reid, 100 A.D.2d 549, 550, 473 N.Y.S.2d 479, 480 (1984) (where defendant seeks sentence credit for jail time spent in another jurisdiction, he must demonstrate that the custody resulted solely from a New York detainer); and Commonwealth v. Bortner, 230 Pa. Super, 64, 67, 326 A.2d 622, 623 (1974) (if defendant is detained in another state solely by reason of Pennsylvania charge and not by reason of separate charges in the other state, then he is entitled to presentence credit).
citation_b.signal: but see
citation_b.identifier: 153 Mich. App. 157, 161
citation_b.parenthetical: even though defendant was incarcerated in another state on unrelated charges, he is entitled to credit for time served in that state from the date that Michigan authorities placed a "hold" on him
citation_b.sentence: But see People v. Ranson, 153 Mich. App. 157, 161, 395 N.W.2d 271, 273 (1986) (even though defendant was incarcerated in another state on unrelated charges, he is entitled to credit for time served in that state from the date that Michigan authorities placed a “hold” on him).