State v. Medrano, 502 P.3d 61

Medrano, previously convicted of statutory rape, was a registered sex offender and in July 2019 failed to pay the registration fee and did not re-register after changing residence; he was arrested and charged with failure to register.
He entered a binding plea agreeing to a unified sentence of five years with two years determinate, suspended, and four years probation.
The judgment required payment of $945.50 (costs, fine, DNA, public defender fee) with payments of $50/month starting March 1, 2020, and contained a clause extending probation "until such time as the defendant has completed payment" if obligations were unpaid at probation expiration.
Medrano timely appealed and moved under Idaho Criminal Rule 35 to correct the sentence, challenging the probation-extension clause as illegal; the district court denied the motion without a hearing, citing I.C. § 20-221.
The State argued the challenge was unripe/speculative because payments could be completed within the four-year term; Medrano argued the clause created an indeterminate probationary term potentially exceeding the statutory maximum.
The Court of Appeals held the probation term was indeterminate and illegal under Idaho statutes requiring a fixed probation term not to exceed the maximum imprisonment for the offense (10 years), reversed the denial, and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the judgment’s probation term—"four years or until financial obligations paid"—is legal	The State: challenge is speculative/unripe; payments likely completed within probation so no illegal term exists	Medrano: clause creates an indeterminate probationary period that may extend beyond the statutory maximum imprisonment (10 years), violating statutes requiring a fixed term	The Court: term is indeterminate and illegal because statutes require a fixed probation term not exceeding the statutory maximum; reversal and remand
Whether the appeal is ripe / this Court has jurisdiction to decide	The State: issue not ripe; contingency unlikely so no present controversy	Medrano: illegality existed on the face of the judgment at entry, so review is proper	The Court: the illegality was facial (present in the judgment) and ripe for review; jurisdiction exists

State v. Josephson, 124 Idaho 286 (Ct. App. 1993) (Rule 35 illegal-sentence standard is a question of law freely reviewable)
State v. Clements, 148 Idaho 82 (2009) (Rule 35 "illegal sentence" is narrowly interpreted as illegal on the face of the record)
State v. Dunne, 166 Idaho 541 (Ct. App. 2020) (trial court exceeds sentencing authority when probation exceeds statutory maximum)
State v. Elias, 157 Idaho 511 (2014) (I.C. § 20-222(1) requires a fixed probation term; 2014 amendment eliminated indeterminate probation)
State v. Kesling, 155 Idaho 673 (Ct. App. 2013) (probation exceeding statutory maximum violates sentencing authority)
State v. Gibbs, 162 Idaho 782 (2017) (modification of probation requires notice and opportunity to be heard)
State v. Fortin, 124 Idaho 323 (Ct. App. 1993) (notice of appeal from judgment includes post-judgment orders denying motion to modify sentence)
State v. Manley, 142 Idaho 338 (2005) (ripeness doctrine requires concrete, present controversy)