State v. Kimberly Rose Hyatt
Background
- Kimberly Rose Hyatt pled guilty to three counts of delivery of a controlled substance (Idaho Code § 37-2732(a)(1)(A)).
- District court imposed concurrent unified sentences of 20 years with 8 years determinate on each count and retained jurisdiction.
- Retained jurisdiction was conditioned on Hyatt’s placement in the therapeutic community; later the court relinquished jurisdiction and executed the sentences without reduction.
- Hyatt filed an Idaho Criminal Rule 35 motion asserting her sentences were illegal because the court conditioned retention of jurisdiction on placement in a specific program.
- The district court denied the Rule 35 motion; Hyatt appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the sentence is "illegal" under I.C.R. 35 because the court conditioned retention of jurisdiction on placement in the therapeutic community | Hyatt: court exceeded authority by conditioning retained jurisdiction on placement in a particular program, making sentence illegal | State: condition was not a direct order committing Hyatt to a facility and the sentence itself is lawful; Rule 35 applies narrowly to facially illegal sentences | Court affirmed denial: sentence not illegal on face of record; Rule 35 inapplicable and no abuse of discretion |
Key Cases Cited
- State v. Clements, 148 Idaho 82, 218 P.3d 1143 (discusses narrow scope of "illegal sentence" under Rule 35)
- State v. Farwell, 144 Idaho 732, 170 P.3d 397 (Rule 35 is narrow to protect finality of judgments)
- State v. Reese, 98 Idaho 347, 563 P.2d 405 (court lacks authority to directly commit a defendant to a particular facility; recommendations entitled to great weight)