State v. Jeffrey Lane Bulletts

Defendant Jeffrey Lane Bulletts pled guilty to possession of methamphetamine; an additional charge was dismissed in exchange for the plea.
The district court imposed a unified five-year sentence with a 1.5-year minimum, suspended the sentence, and placed Bulletts on probation.
Bulletts violated probation; the court revoked probation, ordered execution of the sentence, then retained jurisdiction and later again suspended the sentence and reinstated probation.
Bulletts committed a subsequent probation violation; the court revoked probation and ordered execution of the original suspended sentence.
Bulletts filed an Idaho Criminal Rule 35 motion seeking reduction of sentence; the district court denied the motion.
Bulletts appealed, arguing the court abused its discretion in revoking probation and in denying the Rule 35 motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion in revoking probation	Bulletts contended revocation was an abuse of discretion (implying probation still served rehabilitation goal)	The State argued probation conditions were violated and revocation was within court discretion	Court affirmed: no abuse of discretion in revoking probation
Whether the district court abused its discretion in denying Rule 35 motion for reduction of sentence	Bulletts argued his sentence was excessive and sought leniency under I.C.R. 35 based on new/additional information	The State argued the Rule 35 motion did not show the sentence was excessive given the record and violations	Court affirmed denial: no abuse of discretion; Rule 35 is plea for leniency and Bulletts failed to show the sentence was excessive

State v. Beckett, 122 Idaho 324 (discretion to revoke probation; alternatives include executing or reducing sentence)
State v. Adams, 115 Idaho 1053 (probation revocation standard)
State v. Hass, 114 Idaho 554 (probation revocation standard; rehabilitation and public protection considerations)
State v. Upton, 127 Idaho 274 (court must assess rehabilitation and public safety when considering revocation)
State v. Marks, 116 Idaho 976 (court may reduce sentence under I.C.R. 35 as alternative to execution)
State v. Morgan, 153 Idaho 618 (review focuses on conduct underlying revocation decision)
State v. Knighton, 143 Idaho 318 (Rule 35 is plea for leniency addressed to court's discretion)
State v. Allbee, 115 Idaho 845 (Rule 35 discretion precedent)
State v. Huffman, 144 Idaho 201 (Rule 35 requires showing sentence excessive in light of new/additional information)