In Re the Personal Restraint of Phelan

The issue in this personal restraint peti tion is whether credit against a maximum prison sentence must be given for: (1) time actually served in detention; and (2) time served under the restrictions of probation but not in actual detention. We hold petitioner is not entitled to credit against his maximum sentence for nondetention probationary time, but is entitled to credit for all jail time served exclusively on the principal underlying charge. To the extent petitioner is entitled to the relief stated herein, we grant his personal restraint petition.

Petitioner, Phillip M. Phelan, was…