Idaho Code
Idaho Code

Idaho Code § 20-209A (2026)

Computation of term. 

✓ current as of May 2026
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Computation of term. 

When a person is sentenced to the custody of the board of correction, his term of confinement begins from the day of his sentence. The time during which the person is voluntarily absent from the penitentiary, jail, facility under the control of the board of correction, or from the custody of an officer after his sentence, shall not be estimated or counted as a part of the term for which he was sentenced.

Notes of Decisions
Cited in 10 cases (1 in the last 5 years), 1980–2021 · leading case: State v. Johnson, 618 P.2d 759 (Idaho 1980).
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State v. Johnson, 618 P.2d 759 (Idaho 1980). · cites it 4× “It is beyond any dispute that the sentence first imposed upon Johnson was in all respects a valid sentence.”
State v. Petersen, 241 P.3d 981 (Idaho Ct. App. 2010). · cites it 2× “I.C. § 20-209A. As such, the plain language of I.”
Taylor v. State, 187 P.3d 1241 (Idaho Ct. App. 2008). · cites it 2× “See also I.C. § 20-209A (“A person who is sentenced may receive credit toward service of his sentence for time spent in physical custody pending trial or sentencing, or appeal, if that detention was in connection with the offense for which the sentence was imposed.”
State v. Thomas, 392 P.3d 1239 (Idaho Ct. App. 2017). · cites it 6× “2014); see also I.C. § 20-209A (a person’s term of confinement begins from the day of his or her sentence); State v.”
Chapa v. State, 767 P.2d 282 (Idaho Ct. App. 1989). · cites it 4× “First, he asserts that during his *443 escape he was not “voluntarily” absent from the penitentiary within the meaning of I.C. § 20-209A, 4 following his release by a magistrate in Ada County.”
State v. John Michael Muguira (Idaho Ct. App. 2016). · cites it 8× “The other statute upon which Muguira relies is I.C. § 20-209A, which governs entitlement to credit for time served both before and after sentencing.”
State v. Sean Anthony Thomas (Idaho Ct. App. 2017). · cites it 6× “2014); see also I.C. § 20-209A (a person’s term of confinement begins from the day of his or her sentence); State v.”
State v. Allen (Idaho Ct. App. 2021). · cites it 2× “See I.C. § 20-209A (governing Board of Correction’s calculation of sentences); State v.”
Duaine Fredrick Earl v. State (Idaho Ct. App. 2013). · cites it 2× “We rejected the argument, specifically noting that both section 19-2603 and section 20-209A, make clear that credit for time served is not based on any factor other than actual incarceration, ignoring whether a defendant remained in the Board of Correction’s “custody.”
State v. Robert Louis Stevenson, 339 P.3d 1202 (Idaho Ct. App. 2014). · cites it 2× “See also I.C. § 20-209A (“time during which the person is voluntarily absent from the penitentiary, jail, facility under the control of the board of correction, or from the custody of an officer after his sentence, shall not be estimated or counted as a part of the term for…”
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