State v. Keith Alegria
Background
- Defendant Keith Alegria pled guilty to felony driving under the influence.
- District court imposed a unified ten-year sentence with a three-year minimum, retained jurisdiction, then suspended the sentence and placed Alegria on probation.
- Alegria admitted violating probation; the district court revoked probation and ordered execution of the original sentence.
- Alegria filed an Idaho Criminal Rule 35 motion seeking reduction of sentence; the district court denied the motion.
- Alegria appealed, arguing the revocation was an abuse of discretion, the sentence was excessive, and the Rule 35 denial was error.
- The appellate court reviewed the record (including events before and after original sentencing) and affirmed the revocation, execution of sentence, and denial of Rule 35 relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused its discretion in revoking probation | Alegria: court erred in revoking probation | State: probation violation justified revocation; court acted within discretion | Affirmed — no abuse of discretion in revocation |
| Whether the sentence was excessive | Alegria: sentence (execution of original) is excessive | State: original sentence was within trial court's discretion and appropriate given record | Affirmed — sentence not excessive |
| Whether the district court erred by denying Alegria's I.C.R. 35 motion | Alegria: new/additional information warranted reduction | State: motion is discretionary; no basis shown to reduce sentence | Affirmed — Rule 35 denial proper |
Key Cases Cited
- State v. Beckett, 122 Idaho 324, 834 P.2d 326 (1992) (probation revocation standard and discretion)
- State v. Upton, 127 Idaho 274, 899 P.2d 984 (1995) (revocation considers rehabilitation and public protection)
- State v. Morgan, 153 Idaho 618, 288 P.3d 835 (2012) (review focuses on conduct underlying revocation)
- State v. Hanington, 148 Idaho 26, 218 P.3d 5 (2009) (review of executed sentence includes events pre- and post-sentencing)
- State v. Knighton, 143 Idaho 318, 144 P.3d 23 (2006) (I.C.R. 35 is plea for leniency within court's discretion)
- State v. Huffman, 144 Idaho 201, 159 P.3d 838 (2007) (Rule 35 requires new or additional information to justify reduction)