Izadi (Arman) v. State, 63672

Izadi pleaded guilty to attempted battery with substantial bodily harm under a plea agreement; State promised to not oppose probation and would not oppose treating the crime as gross misdemeanor or felony unless new charges arose
A magistrate in an unrelated case determined probable cause against Izadi for new charges, triggering the State’s ability to argue for any sentence
District court revoked Izadi’s bail pending sentencing after the new-charges probable cause determination
At sentencing, the State argued for a prison term despite the plea agreement’s conditions
Izadi challenged bail revocation timing, lack of an evidentiary hearing, the validity of the plea and the purported bias or errors at sentencing, and the court affirmed the conviction

Issue	Plaintiff's Argument	Defendant's Argument	Held
Bail after guilty plea and its revocation	Izadi argues bail should not have been revoked without a hearing	Izadi asserts a post-plea right to bail and abuse of discretion in revocation	No relief; no constitutional right to bail after conviction; no abuse of discretion shown
Evidentiary hearing before sentencing on new charges	State should present evidence; Izadi claims missing hearing prejudiced him	Plea agreement allowed the State to argue under the circumstances; some charges originated post-plea	No error; no hearing required given the agreement and timing of charges
Validity of stay-out-of-trouble provision and due process	Stay-out provision was illusory and entered in bad faith	Claims challenge plea validity improperly on direct appeal	Not reviewable on direct appeal; plea validity challenges require different procedures
Bias accusations at sentencing and PSI accuracy	Judge showed bias by revoking bail, interrupting counsel, and relying on a faulty PSI	Court’s remarks and reliance on PSI did not demonstrate improper bias; sentence was within statutory range	No abuse of discretion; sentence within range and based on proper considerations

Bergna v. State, 120 Nev. 869 (2004) (no constitutional right to bail after conviction; district court discretion to grant bail pending sentencing)
Sparks v. State, 121 Nev. 107 (2005) (evidentiary hearing not required when plea agreement governs sentencing)
Bryant v. State, 102 Nev. 268 (1986) (plea validity challenges must be raised in district court first)
Parrish v. State, 116 Nev. 982 (2000) (sentencing review limited to abuse of discretion standard)
Allum v. Valley Bank of Nevada, 112 Nev. 591 (1996) (procedural rulings ordinarily do not indicate bias)
Cameron v. State, 114 Nev. 1281 (1998) (remarks in court do not show bias unless mind closed to evidence)
Silks v. State, 92 Nev. 91 (1976) (due-process considerations for sentencing based on admissible evidence)