State v. Michael Anthony Sanchez

Michael Anthony Sanchez pleaded guilty to two counts of robbery, one count of burglary, and one count of grand theft.
The district court imposed concurrent unified sentences: two 30-year terms (15 years determinate each), a 10-year determinate, and a 14-year determinate.
The court suspended execution of the sentences and retained jurisdiction; after a period of retained jurisdiction the court again suspended and placed Sanchez on probation.
Sanchez later admitted to some probation violations and was found to have committed additional violations.
The district court revoked probation and ordered execution of the original suspended sentences.
Sanchez filed an I.C.R. 35 motion which the district court denied; Sanchez appealed the probation revocation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion in revoking probation	Sanchez argued revocation was an abuse of discretion given the circumstances	State argued any proven violation permits revocation and execution of suspended sentence	Court held no abuse of discretion; revocation affirmed

State v. Beckett, 122 Idaho 324, 834 P.2d 326 (Ct. App.) (probation may be revoked for any violated term; court may execute suspended sentence or reduce it)
State v. Adams, 115 Idaho 1053, 772 P.2d 260 (Ct. App.) (standards for probation revocation)
State v. Hass, 114 Idaho 554, 758 P.2d 713 (Ct. App.) (revocation discretion and review)
State v. Upton, 127 Idaho 274, 899 P.2d 984 (Ct. App.) (probation revocation considers rehabilitation and public protection)
State v. Marks, 116 Idaho 976, 783 P.2d 315 (Ct. App.) (court may reduce sentence under I.C.R. 35 after violation)
State v. Morgan, 153 Idaho 618, 288 P.3d 835 (Ct. App.) (review focuses on conduct underlying revocation decision)