State v. Mitchell William Jenkins
Background
- Jenkins pled guilty to possession of a controlled substance (I.C. § 37-2732(c)); other charges were dismissed in exchange for the plea.
- District court imposed a unified seven-year sentence with a two-year minimum, retained jurisdiction, and sent Jenkins to the rider/CAPP program.
- Rider staff recommended probation after Jenkins’s initial retained-jurisdiction period; the court continued the review to allow Jenkins to submit more information.
- The Department of Corrections advised Jenkins needed sex-offender treatment due to prior history; Jenkins agreed to participate, so the court vacated the review and continued retained jurisdiction.
- After completing the rider and sex-offender treatment, the district court relinquished jurisdiction; Jenkins moved under I.C.R. 35 to reduce his sentence, which the court denied.
- Jenkins appealed, arguing the court erred by not granting probation after the first rider and that his sentence was excessive.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether court abused discretion by relinquishing jurisdiction instead of granting probation | Jenkins: probation appropriate after rider; goals of sentencing met by probation | State: district court properly exercised discretion based on rider performance and DOC input | Court: no abuse of discretion; relinquishment affirmed |
| Whether sentence was excessive | Jenkins: sentence longer than necessary; probation would suffice | State: sentence within court’s discretion given facts and prior history | Court: sentence not an abuse of discretion; affirmed |
Key Cases Cited
- State v. Hood, 102 Idaho 711, 639 P.2d 9 (discretion to grant probation)
- State v. Lee, 117 Idaho 203, 786 P.2d 594 (appellate review of probation decisions)
- State v. Burdett, 134 Idaho 271, 1 P.3d 299 (standards for sentence review)
- State v. Sanchez, 115 Idaho 776, 769 P.2d 1148 (factors in sentencing review)
- State v. Reinke, 103 Idaho 771, 653 P.2d 1183 (sentencing review principles)
- State v. Toohill, 103 Idaho 565, 650 P.2d 707 (sentencing review principles)
- State v. Oliver, 144 Idaho 722, 170 P.3d 387 (consider entire sentence on review)