California, United States of America
The following excerpt is from People v. Martinez-Berumen, B232636 (Cal. App. 2012):
For purposes of these calculations, we include the date of the arrest (People v. Lopez (1992) 11 Cal.App.4th 1115, 1124) and the date of sentencing (People v. Smith (1989) 211 Cal.App.3d 523, 525-526). The People concede that appellant is correct that he spent 271 actual days in custody.
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