State v. Gorringe, 481 P.3d 723

In May 2011 the magistrate entered a standard-form no-contact order (expiring May 25, 2012).\
Gorringe pleaded guilty to attempted strangulation; at sentencing the court rescinded the magistrate order but incorporated no-contact provisions into the January 30, 2012 Judgment and Commitment rather than using the separate Rule 46.2 form.\
The 2012 Judgment’s no-contact language omitted required elements (no termination date, no distance restriction, no penalty advisories) and was not on the separate form.\
Gorringe appealed in 2012 on a Rule 5.1 ground only; the Court of Appeals affirmed and remittitur issued in March 2013.\
In 2017–18 Gorringe was charged with a misdemeanor for allegedly violating the 2012 no-contact provision; the parties stipulated to an amendment of the 2012 order (and dismissal of the misdemeanor), and the district court—though doubtful it had jurisdiction—entered the amendment.\
The Idaho Supreme Court reversed: the 2012 no-contact provisions were unenforceable for failing to comply with I.C.R. 46.2, and the district court lacked subject-matter jurisdiction to amend the final judgment after remittitur.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of the 2012 no-contact provision	The State: order was effectively validated by later stipulation and amendment	Gorringe: the provision never complied with I.C.R. 46.2 (no expiry, no distance, no penalty notice; not on separate form)	The provision was unenforceable for failing to meet Rule 46.2 requirements
Whether law-of-the-case bars challenge	The State: Gorringe should have raised validity on his 2012 appeal	Gorringe: no reason to challenge then because earlier magistrate order indicated an expiration in 2012	Law-of-the-case did not bar the challenge; jurisdictional issues may be raised anytime
Whether the district court had jurisdiction to amend in 2018	The State: parties stipulated and victim consented; amendment cured defects	Gorringe: once judgment became final after remittitur, court lost jurisdiction; parties cannot confer subject-matter jurisdiction	Court lacked subject-matter jurisdiction to amend a final judgment; the amendment was void

State v. Castro, 145 Idaho 173 (explaining Rule 46.2 history and directing termination dates on no-contact orders)
State v. Cobler, 148 Idaho 769 (holding Rule 46.2 requires an expiration date)
State v. Hillbroom, 158 Idaho 789 (stressing compliance with Rule 46.2 content requirements)
State v. Jakoski, 139 Idaho 352 (finality of judgment extinguishes trial court jurisdiction absent statutory rule)
Fairway Dev. Co. v. Bannock Cnty., 119 Idaho 121 (parties cannot create subject-matter jurisdiction by stipulation)
State v. Lute, 150 Idaho 837 (orders entered without subject-matter jurisdiction are void and subject to collateral attack)
State v. McIntosh, 160 Idaho 1 (jurisdiction in criminal cases is conferred by filing of charging document)