State v. Carey Mitchell Baker, 322 P.3d 291

Baker and Shea married in 2005 and divorced in 2009.
A 2009 civil protection order was issued against Baker.
Between May and December 2009 Baker sent eleven messages to Shea in violation; one message occurred in Ada County, the rest in Kootenai County.
Boise filed Ada County charges (one count) for the Ada message; Coeur d’Alene filed twelve counts in Kootenai County; arrest warrant issued in Kootenai County.
Baker pled guilty in Ada County on February 27, 2010 to the Ada County charge with a plea that the State would pursue no other charges arising from violations prior to February 17, 2010.
The district court vacated the eleven Kootenai County convictions, holding the Ada County plea bound the Coeur d’Alene County prosecutor; the State appeals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Kootenai County charges are barred by the plea agreement.	Baker; the Ada plea binds all prosecutions by the State.	State; plea did not clearly bind Kootenai County.	Yes; the Kootenai charges were barred by the plea.
Whether specific performance was proper relief for breach of the plea agreement.	Baker seeks dismissal via specific performance.	Withdrawal of plea was the proper remedy.	Yes; specific performance was proper relief.

Santobello v. New York, 404 U.S. 257 (U.S. 1971) (promises in plea agreements must be fulfilled; breach invalidates plea)
State v. Peterson, 226 P.3d 535 (Idaho 2010) (contract-law standards govern plea-agreement interpretation; ambiguities resolved in defendant’s favor)
State v. Cope, 129 P.3d 1241 (Idaho 2006) (contract-interpretation standard for plea agreements)
State v. Wills, 102 P.3d 380 (Ct. App. 2004) (remedies for breached plea agreements; specific performance or withdrawal)
State v. Lampien, 223 P.3d 750 (Idaho 2009) (prosecution duties and state’s authority in criminal actions)
Amerson, 925 P.2d 399 (Ct. App. 1996) (venue and prosecutorial authority related to multi-county prosecutions)