State v. Clayton Robert Adams
Background
- Adams was convicted of second-degree murder and aggravated battery; in 2007 the court imposed a life term (25-year minimum) for murder and a 10-year term (3-year minimum) for battery, ordered to run consecutively.
- Adams filed post-conviction relief; the district court found trial counsel ineffective on a sentencing-standards issue and granted partial relief by ordering a resentencing hearing for the murder conviction only.
- At the 2014 resentencing, the court reimposed the same murder sentence; an amended judgment noted the original aggravated-battery sentence would remain as before.
- Adams moved under I.C.R. 35 for credit for time served on the aggravated-battery sentence, arguing the consecutive relationship became concurrent because the court did not orally reimpose the consecutive order at resentencing and because the original murder sentence was effectively vacated by granting resentencing.
- The district court denied the I.C.R. 35 motion; the Court of Appeals affirmed, concluding the post-conviction order did not vacate the original murder sentence and the resentencing court was not required to readdress the battery sentence.
Issues
| Issue | Adams' Argument | State's Argument | Held |
|---|---|---|---|
| Did the grant of post-conviction relief and order of resentencing vacate Adams's original murder sentence so the battery sentence could no longer run consecutively? | Granting resentencing effectively vacated the original murder sentence, leaving no contemporaneous sentence for the battery to run consecutive to. | The post-conviction proceeding is separate; the grant of resentencing did not vacate the original sentence and the battery sentence remained consecutive. | The court held the post-conviction order did not vacate the original murder sentence; the battery sentence remained contemporaneous and consecutive. |
| Was the district court required to orally reimpose the consecutive nature of the battery sentence at the resentencing hearing for that consecutive effect to continue? | Because the court did not orally pronounce the sentences as consecutive at resentencing, the written amended judgment could not reinstate the consecutive relationship. | The resentencing was limited to the murder sentence; the battery sentence and its consecutiveness were unaffected and need not be readdressed orally at resentencing. | The court held no oral pronouncement was required at the limited resentencing; the amended judgment correctly reflected the continuing consecutive sentence. |
| Is Adams entitled to I.C. § 18-309 credit for time served on the battery sentence dating from the original 2007 sentence because it became concurrent? | If sentences became concurrent, Adams should receive credit from 2007 on the battery count. | Credit under §18-309 is limited to actual pre-judgment confinement and depends on whether the sentence remained consecutive; it did. | The court denied credit; Adams failed to show his consecutive sentence became concurrent. |
| Standard of review for credit-for-time-served rulings | (implicit) | (implicit) | Legal questions reviewed de novo; factual findings defer to district court. |
Key Cases Cited
- State v. Moore, 156 Idaho 17, 319 P.3d 501 (Ct. App.) (I.C. § 18-309 mandates credit only for actual pre-judgment incarceration)
- State v. Law, 131 Idaho 90, 952 P.2d 905 (Ct. App.) (post-conviction relief is a separate civil action and remedies are carried out by reopening the criminal case)
- State v. Dreier, 139 Idaho 246, 76 P.3d 990 (Ct. App.) (oral pronouncement controls over written judgment when they conflict)
- State v. Justice, 152 Idaho 48, 266 P.3d 1153 (Ct. App.) (modifying one sentence does not necessarily alter other consecutive sentences)