State v. Charles Earl Guess, 154 Idaho 521

Charles Guess pleaded guilty to one count of aggravated assault under a written plea agreement with a five-year probation; the court withheld judgment and imposed probation; victim Ms. Guess remained fearful; Guess sought to withdraw the plea and dismiss the charge after probation; district court denied multiple relief motions; on appeal Guess challenges the enforceability of the relief under Idaho Code §19-2604(1).
The written plea agreement did not promise withdrawal of the plea upon probation completion and prohibited oral amendments that would create such a promise.
The district court instructed the colloquy did not modify the written agreement and did not create an entitlement to withdrawal.
Probation period was five years, not extended by denial of withdrawal; trial court acted within its statutory discretion.
The court recognized discretion under §19-2604(1), applied the Four-Part test, and denied relief because fear of the victim and statutory requirements were not satisfied.
This Court affirms the district court’s denial of Guess’s motion to withdraw the guilty plea and dismiss the charge.

Issue	Plaintiff's Argument	Defendant's Argument	Held
May a plea agreement promise withdrawal upon probation completion?	Guess: yes, relief promised by terms.	State: no, such promise not allowed by statute.	No; such a provision is void.
Did the colloquy modify the written plea agreement?	Guess: dialogue altered terms.	State: no modification.
No modification occurred.
Was the denial of withdrawal an indefinite extension of probation or due process violation?	Guess: extended probation; due process harmed.	Court properly denied; five-year probation intact.	Not an extension; within discretion.
Did the district court abuse discretion in denying relief?	Guess: relief should be granted for compliance and fear.	Court exercised discretion, considered victim’s fear.	No abuse; denial affirmed.

State v. Funk, 123 Idaho 967 (Idaho 1993) (cannot promise withdrawal upon probation when not authorized by statute)
State v. Branson, 128 Idaho 790 (Idaho 1996) (withheld judgment relief must comply with statutory limits)
State v. Gomez, 281 P.3d 90 (Idaho 2012) (written plea governs; extrinsic evidence limited)
Rife v. Long, 908 P.2d 143 (Idaho 1995) (statutory discretion; 'may' implies discretion to grant relief)
State v. Hardwick, 249 P.3d 379 (Idaho 2011) (discretionary relief under §19-2604(1) requires proper findings)
State v. Dieter, 291 P.3d 413 (Idaho 2012) (public interest compatibility standard; discretionary focus on public—not private—interests)
Athay v. Stacey, 128 P.3d 897 (Idaho 2005) (statutory construction guiding interpretation of relief provisions)