State v. Cameron Everett Post
Background
- Defendant Cameron Everett Post pleaded guilty to involuntary manslaughter (I.C. § 18-4006(2)) and use of a deadly weapon (I.C. § 19-2520).
- District court imposed a unified 10-year sentence (2 years determinate) for manslaughter and a consecutive unified 5-year sentence (2 years determinate) for the weapon enhancement.
- Post filed an Idaho Criminal Rule 35 motion seeking reduction of sentence based on additional information (restitution uncertainty, financial hardship to family, prison placement, etc.).
- The district court denied the I.C.R. 35 motion, concluding the information was largely a restatement of matters already considered and did not justify leniency.
- Post appealed, challenging both the reasonableness of his sentence and the denial of his I.C.R. 35 motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the overall sentence was an abuse of discretion | Post: sentence is excessive/unreasonable | State/District: sentence within trial court discretion after considering relevant factors | Affirmed — no abuse of discretion; sentence upheld |
| Whether denial of I.C.R. 35 motion was erroneous | Post: presented new/additional information (restitution uncertainty, family hardship, placement) justifying reduction | State/District: information was not new or sufficient; court properly considered and rejected it | Affirmed — denial proper; no abuse of discretion |
Key Cases Cited
- State v. Hernandez, 121 Idaho 114 (1991) (standards for sentencing review)
- State v. Lopez, 106 Idaho 447 (1984) (factors for reasonableness of sentence)
- State v. Toohill, 103 Idaho 565 (1981) (sentencing discretion principles)
- State v. Oliver, 144 Idaho 722 (2007) (review considers entire sentence)
- State v. Knighton, 143 Idaho 318 (2006) (I.C.R. 35 as plea for leniency)
- State v. Allbee, 115 Idaho 845 (1989) (I.C.R. 35 addressed to court's discretion)
- State v. Huffman, 144 Idaho 201 (2007) (I.C.R. 35 requires new or additional information)
- State v. Forde, 113 Idaho 21 (1986) (review of I.C.R. 35 uses same criteria as sentence reasonableness)