State v. Matthews, 434 P.3d 209

Matthews was arrested on a parole absconder warrant at a residence; during booking two baggies of methamphetamine were found on his person and he was charged with possession.
Matthews moved to suppress the evidence; the motion was denied and he entered an open guilty plea to possession, with an agreed restitution component for prosecution costs.
At sentencing the State sought $200 for lab fees and $524.12 for prosecution costs; the court awarded the lab fees and court costs but declined to order the full prosecution-cost restitution, citing Matthews’ statement that he would rather pay court costs than pay for exercising his constitutional rights.
Matthews was sentenced to a unified seven-year term with three years fixed and appealed, arguing the sentence was excessive and the court ignored mitigating factors.
The State cross-appealed the refusal to award full prosecution costs under Idaho Code § 37-2732(k), arguing the court’s stated reason conflicted with this Court’s precedent (State v. Kelley).
The Idaho Supreme Court affirmed: it held the sentence was within the court’s discretion given Matthews’ criminal history and denied that the district court abused its discretion in partially denying prosecution-cost restitution.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the seven-year sentence (3 years fixed) was excessive	Sentence is reasonable and supported by record and sentencing standards	Matthews: sentence excessive given minor possession, character letters, addiction, nonviolent offense	Affirmed — within discretion given lengthy criminal history, supervision violations, denial of responsibility
Whether district court abused discretion by denying full prosecution-cost restitution under I.C. § 37-2732(k)	State: court’s rationale (that awarding costs chills constitutional rights) conflicts with this Court’s ruling in Kelley and thus was inconsistent with legal standards	Matthews: court appropriately exercised discretion and considered factors (including future earning ability) in awarding partial restitution	Affirmed — court did not abuse discretion; awarding some costs shows intent to apply statute and the court’s comment was not the sole basis for denying full restitution

State v. Kelley, 161 Idaho 686, 390 P.3d 412 (Idaho 2017) (held § 37-2732(k) does not impermissibly chill Sixth Amendment rights or violate equal protection)
State v. Cunningham, 161 Idaho 698, 390 P.3d 424 (Idaho 2017) (restitution under § 37-2732(k) is discretionary; court may consider factors like fines, victim restitution, assets, and earning ability)
State v. Varie, 135 Idaho 848, 26 P.3d 31 (Idaho 2001) (appellant must show sentence excessive under any reasonable view of the facts)
State v. Miller, 151 Idaho 828, 264 P.3d 935 (Idaho 2011) (when sentence is within statutory limits, appellant bears burden to show clear abuse of discretion)