State v. Krystal Lynn Easley, 156 Idaho 214

Easley was charged in 2005 with possession of a controlled substance and entered an Alford plea; the district court sentenced four years with two fixed but suspended, placing her on probation.
She admitted to probation violations in 2007 for failing to contact the probation officer, absconding, failing to maintain employment, and failing to pay costs; probation was revoked and reinstated.
In 2010, the State sought probation revocation and Easley pled guilty to a new possession charge; she also admitted to various probation violations and the court imposed a concurrent seven-year unified sentence with three years fixed, retaining jurisdiction.
In 2011–2012, motions to revoke probation were filed in both cases; Easley objected to the process by which the prosecutor could veto mental health court eligibility post-judgment.
On January 31, 2012, the district court revoked probation and executed the sentences, but sua sponte reduced the second case to a seven-year unified sentence with two and a half years fixed; Easley appealed and sought augmentation of the record; the court partially granted augmentation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the record augmentation denial violated due process or equal protection	Easley argues denial deprived effective appellate review	State argues only germane transcripts needed for probation revocation review	No due process violation; augmentation limited to germane materials
Whether prosecutor's post-judgment veto of mental health court violates separation of powers	Easley asserts veto preserves judicial authority over sentencing	State contends prosecutor may veto eligibility	Prosecutorial veto violates separation of powers; court must retain sentencing authority
Whether prosecutorial veto violates uniform judicial powers doctrine	Easley claims district practices create class-specific rules	State argues issue not needed for review	Issue not necessary to decide; veto deemed void where it exists
Whether the district court abused discretion in revoking probation	Easley contends mental health issues nonwillful and require alternatives	State maintains clear probation violations	Probation revocation improper where alternatives (mental health court) were not considered
Whether the court should have sua sponte further reduce Easley's sentence	Easley seeks further reduction given mental health considerations	State argues discretion to determine sentence	Court remanded for resentencing and consideration of all sentencing alternatives

Griffin v. Illinois, 351 U.S. 12 (U.S. 1956) (indigent defendant entitled to free trial transcripts for meaningful appeal)
Draper v. State, 372 U.S. 487 (U.S. 1963) (state must provide an adequate transcript or alternative for indigents)
Mayer v. City of Chicago, 404 U.S. 189 (U.S. 1971) (burden on state to show adequacy of alternatives for appeal)