State v. Daryel Rawls (072388)

The issue on appeal is whether a defendant who is released on bail on one indictment, but subsequently incarcerated on a later indictment, is entitled to jail credit against the former indictment under Rule 3:21-8 (Credit for Confinement Pending Sentence).

Defendant Daryel Rawls was indicted on drug-related charges in Union County, made bail, but was later arrested for unrelated offenses in Ocean County. Defendant spent 155 days in Ocean County custody before he pled guilty to his Union County charges and his bail was formally revoked. The trial court denied defendant’s motion to receive jail…