State v. Allen, 156 Idaho 332

Allen pled guilty to attempted strangulation under a plea agreement; judgment of conviction entered 1/13/2010 with a 3-year sentence, 1-year determinate, suspended, probation for 3 years.
State filed probation-violation allegations ~9 months after sentencing; Allen admitted one violation, others dismissed; district court found probation violation but continued probation with 8 days in county jail.
In December 2011, Allen moved to terminate probation early, set aside the probation violation, and relief under I.C. § 19-2604 to set aside the guilty plea and dismiss the case; district court denied, but converted probation to unsupervised in 12/2011.
Allen later moved to terminate unsupervised probation early and renewed requests to reduce felony to misdemeanor and set aside the violation; district court granted early termination but denied remaining relief, citing public interest.
Allen petitioned for reconsideration and moved to seal the criminal file; district court denied both; Allen appealed.
On appeal, Allen challenges (i) the denial of relief under § 19-2604 to reduce the conviction, and (ii) the denial of sealing the criminal file; the court affirms both in part and discusses statutory framework and public-interest considerations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court erred in denying reduction of the felony conviction under § 19-2604.	Allen contends court abused discretion by finding reduction not compatible with public interest.	State argues no relief should be granted due to probation-violation findings and Guess framework.	The district court erred by misapplying § 19-2604, but relief denied regardless under current facts.
Whether the district court abused its discretion by denying sealing of the record under Rule 32(i).	Allen asserts privacy and third-party information justify sealing.	State argues public access outweighs privacy; seal not warranted.	No abuse of discretion; public interest overrides privacy, sealing denied.

State v. Guess, 154 Idaho 521 (2013) (controls district court authority under §19-2604 in probation-withdrawal contexts; threshold findings required)
State v. Hanes, 139 Idaho 392 (Ct. App. 2003) (probation compliance is prerequisite to relief; noncompliance precludes relief)
State v. Werneth, 101 Idaho 241 (1980) (affirming on correct theory where trial court's reasoning was alternate; policy on relief thresholds)