State v. Junior Larry Hilbroom, 352 P.3d 999

In June–September 2012, a magistrate court issued and later modified a no-contact order prohibiting Junior Hillbroom from contacting the alleged victim; each order left the expiration date blank (did not state a specific calendar date).
Hillbroom was charged in a separate citation with misdemeanor violation of the no-contact order under Idaho Code § 18-920(2).
Hillbroom moved to dismiss the violation charge arguing the no-contact order was invalid because it failed to comply with Idaho Criminal Rule 46.2(a)(3)’s requirement of a specific expiration date.
Lower courts (magistrate, district acting as appellate court, Court of Appeals) denied dismissal and affirmed conviction; this Court granted review.
The Supreme Court acknowledged the magistrate’s noncompliance with I.C.R. 46.2(a)(3) but addressed whether that procedural error required vacating Hillbroom’s conviction under I.C. § 18-920(2).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a no-contact order lacking the specific-expiration-date required by I.C.R. 46.2(a)(3) fails to satisfy the “no contact order has been issued” element of I.C. § 18-920(2)(b)	The State: the court-issued no-contact order satisfied § 18-920(2)(b) despite procedural defects	Hillbroom: the order was invalid under I.C.R. 46.2(a)(3); absent a valid order the § 18-920(2) violation cannot be proved	The Court held the plain language of § 18-920(2)(b) is satisfied by a court-issued no-contact order even if the order failed to include the specific expiration date; Hillbroom’s conviction affirmed

State v. Cobler, 148 Idaho 769 (court expectes compliance with I.C.R. 46.2 requirements)
State v. Castro, 145 Idaho 173 (explaining public interests served by expiration dates on no-contact orders)
State v. Herren, 157 Idaho 722 (discussing I.C.R. 46.2 as procedural rule and interpreting disjunctive language in statutes)
State v. Owens, 158 Idaho 1 (statutory interpretation principles: plain language controls)
State v. Weber, 140 Idaho 89 (exercise of free review over interpretation of statutes and criminal rules)