State of Tennessee v. Leonard H. Steele

The defendant, Leonard H. Steele, pled guilty to driving on a revoked license, third offense, and was sentenced to eleven months and twenty-nine days, suspended except for six months in the county jail, with the balance to be served on supervised probation. On appeal, he argues that the trial court erred by denying him jail credit for time he served in 1998 as a motor vehicle habitual offender (MVHO) in an unrelated case, even though, unknown to him, his MVHO status had been withdrawn in 1997. Following our review, we affirm the judgment of the trial court.