State v. Philip L. Dieter, 153 Idaho 730

Dieter pled guilty to lewd conduct in 1988 with withheld judgment and probation; an Order Withholding Judgment and Order of Probation imposed five years of probation and stated dismissal upon full compliance.
Second Amended Order (1990) expanded probation terms.
1992 order terminated probation, dissolved orders, and withheld judgment; no explicit dismissal.
1999 expungement motion denied; 2010 Dieter moved to dismiss under I.C. § 19-2604(1) alleging compliance at all times.
2011 evidentiary hearing; court denied motion to dismiss, citing public interest and probation history; Dieter appeals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court lacked jurisdiction or discretion to deny the motion to dismiss.	Dieter argues Hartwig limits authority to amend final orders.	State contends court did not amend final orders and had discretion to deny.	District court had jurisdiction and discretion to deny.
Whether the district court erred in denying the motion to dismiss under I.C. § 19-2604(1).	Dieter asserts rehabilitation and public interest favor dismissal.	State contends sufficient evidence and public-interest analysis supported denial.	Court did not abuse discretion; denial affirmed.

State v. Jones, 140 Idaho 755 (2004) (standard for jurisdiction and discretion review in criminal dismissals)
State v. Wiedmeier, 121 Idaho 189 (1992) (probation termination and dismissal discretion when sentence withheld)
State v. Gurney, 152 Idaho 502 (2012) (burden on movant to prove grounds for dismissal; discretion balanced with public policy)
State v. Hartwig, 150 Idaho 326 (2011) (limits on district court authority to amend final orders; distinguishing Hartwig from current case)
State v. Thompson, 140 Idaho 796 (2004) (compliance standard under 19-2604(1); substantial compliance not sufficient)
Heller v. Cenarrusa, 106 Idaho 571 (1984) (private attorney general doctrine and public-interest considerations)
State v. Hagerman Water Right Owners, Inc., 130 Idaho 718 (1997) (public-interest litigant standard and societal public-interest considerations)