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Name: People v. Ravaux
Case #: D047496
Court: CA Court of Appeal
District 4 DCA
Division: 1
Opinion Date: 08/16/2006

A criminal defendant is not entitled to custody credits for time spent in police custody prior to official booking. The appellate court rejected the argument that “custody” for purposes of Penal Code section 2900.5 should be determined using the standard articulated in Miranda v. Arizona (1966) 384 U.S. 436. The plain language of the statute addresses only residential custody situations. Thus, the defendant was not entitled to credits from the time of his arrest on the night of December 2, but was only entitled to credits from the time that he was officially booked into jail, early in the morning of December 3.