State v. Gurney, 152 Idaho 502

Gurney pled guilty to possession of marijuana with intent to deliver, a felony under Idaho Code § 37-2732(a)(1)(B).
On the same day, he entered Idaho drug court and performed exceptionally well while a full-time student and two-employed worker.
Upon successful completion, he moved to set aside the guilty plea and dismiss the case under Idaho Code § 19-2604(1) and to seal the records under I.C.A.R. 32.
The district court granted dismissal but denied sealing of the records, leading to a motion for reconsideration and a supplemental affidavit.
Gurney also moved to amend the appeal caption to conceal his identity; the district court denied this request.
Gurney timely appealed the district court’s denial of sealing his records and the caption-amendment denial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court erred sealing records under I.C.A.R. 32	Gurney: economic harm shifts burden to the State to show public interest outweighs privacy.	Gurney: public interest must be overcome; court should weigh privacy first.	No error; public interest predominates; burden on moving party; district court acted within discretion.
Whether diminution of public disclosure over time was required to be considered	Gurney: time diminishes public interest due to completion of program.	Gurney failed to cite authority; issue waived.	Waived for lack of authority.
Whether district court erred by comparing to Turpen	Gurney: Turpen precedent applies; public interest should be lower for similar cases.	Gurney: Turpen distinguished; felony vs misdemeanor; error if misapplied.	No reversible error; district court distinguished appropriately; argument waived for lack of authority.
Whether district court erred in denying caption amendment	Gurney sought to change title to conceal identity.	Rule 6 allows only retention; caption amendment requires absence of error.	Denied; title remained correct; amendment inappropriate.

State v. Turpen, 147 Idaho 869 (2009) (burden for Rule 32(i) determinations rests with the movant)
State v. Zichko, 129 Idaho 259 (1996) (waiver for lack of authority or authority support on appeal)
In re City of Shelley, 151 Idaho 289 (2011) (jurisdictional and burden principles in sealing records; predictive authority)