State v. David N. Hyatt

David N. Hyatt pleaded guilty in two cases: failure to register as a sex offender (Docket No. 43139) and felony DUI (Docket No. 43142); both resulted in suspended unified sentences with probation and retained jurisdiction.
Hyatt repeatedly violated probation (batteries, alcohol use, DUI, violating protection orders, harboring a runaway, associating with prohibited persons); multiple probation violations spanned 2010–2015.
The district court revoked probation in both cases after finding willful violations and ordered execution of the original concurrent sentences (four years with two determinate in 43139; three years with one determinate in 43142).
Parties initially stipulated to credit for pre‑judgment jail time (451 days in 43139; 442 days in 43142); Hyatt later filed amended I.C.R. 35 motions asserting the stipulated figures were mistaken and seeking larger credits based on sheriff’s records.
Hyatt also filed I.C.R. 35 motions seeking reduction of sentence (leniency) based on new information about hardship to his wife; the district court denied those motions.
On appeal, the Court of Appeals affirmed the revocation and denial of leniency but reversed and remanded the denial of the amended I.C.R. 35 motions for credit for time served for the district court to decide the merits of the corrected credit claims.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Hyatt)	Held
Whether revocation of probation was an abuse of discretion	Court may revoke when probation terms violated; continued probation would threaten public safety	Revocation unnecessary for rehabilitation; deserves another chance, mental health/medication caused behavior, family hardship	Affirmed — court did not abuse discretion; repeated violent violations and long criminal history showed probation failed rehabilitation and endangered society
Whether I.C.R. 35 reduction (leniency) should be granted based on new information	Sentences appropriate given history and need for protection, deterrence, retribution	Wife’s health/financial hardship and changed circumstances make sentences excessive	Affirmed — defendant failed to show sentence excessive in light of new info
Whether amended I.C.R. 35 motions for corrected credit for time served should be denied because counsel stipulated earlier	Trial court relied on prior stipulation to deny re‑calculation	Sheriff’s records show the originally stipulated days were incorrect; defendant entitled to accurate credit under I.C. § 18‑309	Reversed & remanded — district court must determine correct pre‑judgment custody credit from the record and rule on the merits
Whether district court erred by failing to assess willfulness of violations	(Withdrawn on appeal)	Argued district court didn’t determine willfulness	Not addressed on appeal (argument withdrawn)

State v. Beckett, 122 Idaho 324 (court may revoke probation when terms violated)
State v. Adams, 115 Idaho 1053 (probation revocation discretion)
State v. Hass, 114 Idaho 554 (probation revocation and considerations)
State v. Sanchez, 149 Idaho 102 (review scope for probation revocation)
State v. Upton, 127 Idaho 274 (rehabilitation and public protection standards)
State v. Hedger, 115 Idaho 598 (appellate review of discretionary decisions)
State v. Knighton, 143 Idaho 318 (I.C.R. 35 is plea for leniency)
State v. Allbee, 115 Idaho 845 (I.C.R. 35 standard)
State v. Huffman, 144 Idaho 201 (I.C.R. 35 requires showing sentence excessive given new information)
State v. Forde, 113 Idaho 21 (review of I.C.R. 35 under original sentence reasonableness)
State v. Moore, 156 Idaho 17 (mandatory statutory entitlement to correct credit for pre‑judgment incarceration)
State v. Hernandez, 120 Idaho 785 (credit limited to actual pre‑judgment confinement)