Jeter v. State
2017 Alas. App. LEXIS 28
| Alaska Ct. App. | 2017Background
- Jeter committed a new crime while on probation for earlier offenses; he received a sentence for the new crime and separate probation-revocation sentences in the earlier cases.
- The Court of Appeals initially held that the new-crime sentence and the related revocation sentences must be treated as a single composite sentence on appeal and warned defendants to provide records from all related cases.
- The Office of Public Advocacy and the Public Defender Agency requested rehearing/clarification; the court granted rehearing and solicited supplemental briefing.
- The court recognized practical differences: new-crime sentencing and revocation sentencing often occur before different judges at different times and serve different legal purposes.
- The court concluded that treating such sentences categorically as a single composite unit, or requiring appeals of all related sentences to challenge one, is inappropriate in many cases.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a direct sentence for a new crime and related probation-revocation sentences must be reviewed only as a single composite sentence | Court (initially): composite review is required because multiple sentences often reflect a single overall sentencing choice | Jeter: individual sentences should be reviewable separately | Court (on rehearing): disavows categorical composite rule; sentences may be appealed individually depending on context |
| Whether a defendant must appeal all related sentences to challenge any one sentence | Court (initially): defense should supply records of all related proceedings; may decline appeals lacking full record | Jeter: should be allowed to appeal an individual sentence without appealing all related sentences | Court: rejects a categorical requirement to appeal all related sentences; parties may supplement the record if earlier sentences are relevant |
Key Cases Cited
- Richards v. State, 249 P.3d 303 (Alaska App. 2011) (discusses composite sentencing review when multiple sentences are imposed in a single proceeding)
- Moya v. State, 769 P.2d 447 (Alaska App. 1989) (prior authority partially disavowed by this opinion)
- Steve v. State, 875 P.2d 110 (Alaska App. 1994) (prior authority partially disavowed by this opinion)
- Smith v. State, 187 P.3d 511 (Alaska App. 2008) (requires consecutive sentencing for new-crime and revocation sentences)
- McKinnon v. State, 526 P.2d 18 (Alaska 1974) (establishes that revocation proceedings are a continuation of the underlying criminal case)