State v. Christopher Lee Green
Background
- Christopher Lee Green pleaded guilty under an Alford plea to possession of methamphetamine (Idaho Code § 37-2732(c)(1)).
- The district court imposed a unified five-year sentence with two years determinate, suspended the sentence, and placed Green on probation.
- Green admitted violating probation; the district court revoked probation and ordered execution of the previously suspended sentence.
- Green filed an Idaho Criminal Rule 35 motion seeking reduction of the executed sentence; the district court denied the motion.
- Green appealed, arguing the district court abused its discretion in (1) revoking probation and executing the sentence and (2) denying his I.C.R. 35 motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused its discretion by revoking Green's probation | Green argued revocation was excessive/unsupported by record | State argued probation violation occurred and court properly weighed rehabilitation and public safety | Court affirmed: no abuse of discretion in revoking probation or executing sentence |
| Whether the district court abused its discretion in denying Green's I.C.R. 35 motion for reduction of sentence | Green argued sentence was excessive and presented new/additional information warranting reduction | State argued no new information showed the sentence was excessive and denial was within discretion | Court affirmed: I.C.R. 35 denial was not an abuse of discretion |
Key Cases Cited
- State v. Beckett, 122 Idaho 324 (Ct. App. 1992) (standard for probation revocation and available remedies)
- State v. Upton, 127 Idaho 274 (Ct. App. 1995) (probation revocation requires balancing rehabilitation and public protection)
- State v. Morgan, 153 Idaho 618 (Ct. App. 2012) (focus on underlying conduct supporting revocation on appeal)
- State v. Knighton, 143 Idaho 318 (2006) (I.C.R. 35 is plea for leniency within court’s discretion)
- State v. Huffman, 144 Idaho 201 (2007) (I.C.R. 35 requires showing sentence excessive in light of new or additional information)
- North Carolina v. Alford, 400 U.S. 25 (1970) (governs guilty pleas entered while maintaining innocence)