State v. Andrea Rose Geissler

Andrea Rose Geissler pled guilty to felony domestic battery (I.C. §§ 18-903, -918) in Docket No. 45220 and felony possession of methamphetamine (I.C. § 37-2732(c)(1)) in Docket No. 45221; additional charges were dismissed in plea bargains.
District court imposed unified terms (6 years with 3 determinate for battery; 5 years with 2 determinate for possession) but retained jurisdiction in both cases.
After Geissler successfully completed retained jurisdiction, the court suspended the sentences and placed her on five years’ probation.
Geissler later admitted violating probation; the district court revoked probation and ordered execution of the original suspended sentences.
Geissler appealed only the probation revocation, not the sentence lengths.

Issue	Geissler's Argument	State's Argument	Held
Whether district court abused its discretion in revoking probation	Revocation was an abuse of discretion (insufficient grounds or disproportionate)	Probation conditions were violated and court acted within discretion to protect society and pursue rehabilitation	Court affirmed: no abuse of discretion in revocation or executing suspended sentences

State v. Beckett, 122 Idaho 324, 834 P.2d 326 (Ct. App. 1992) (probation may be revoked for violation; court may execute or reduce sentence)
State v. Adams, 115 Idaho 1053, 772 P.2d 260 (Ct. App. 1989) (standard for probation revocation discretion)
State v. Hass, 114 Idaho 554, 758 P.2d 713 (Ct. App. 1988) (probation revocation and court’s discretionary scope)
State v. Upton, 127 Idaho 274, 899 P.2d 984 (Ct. App. 1995) (revocation requires balancing rehabilitation and public protection)
State v. Marks, 116 Idaho 976, 783 P.2d 315 (Ct. App. 1989) (court may order retained jurisdiction after revocation)
State v. Morgan, 153 Idaho 618, 288 P.3d 835 (Ct. App. 2012) (review focuses on conduct underlying revocation decision)