State v. Poetrius C. Giovanni

Giovanni pled guilty to two counts of grand theft (Docket Nos. 44607, 44608) and received consecutive unified six-year sentences with two-year minimum confinements.
In Docket No. 44607 the court retained jurisdiction, sent Giovanni to the rider program, then suspended the sentence and placed him on probation after successful completion.
In Docket No. 44608 the court imposed a consecutive six-year sentence; Giovanni’s later conduct led to admission of a probation violation in 44607 and execution of that sentence, but the court again retained jurisdiction and reinstated probation after the rider.
Giovanni was later charged with a new crime, admitted violations of probation in both cases, and the district court revoked probation in both matters and again retained jurisdiction before this appeal.
Giovanni appealed, arguing the district court abused its discretion in revoking probation.

Issue	Giovanni's Argument	State's Argument	Held
Whether the district court abused its discretion in revoking probation	Revocation was an abuse of discretion (implied challenge to sufficiency/reasonableness of revocation)	Probation revocation is appropriate when terms are violated and protects society/rehabilitation goals	Court affirmed: no abuse of discretion in revoking probation

State v. Beckett, 122 Idaho 324, 834 P.2d 326 (1992) (standards for revocation discretion and available options after violation)
State v. Adams, 115 Idaho 1053, 772 P.2d 260 (1989) (probation revocation discretion)
State v. Hass, 114 Idaho 554, 758 P.2d 713 (1988) (probation revocation principles)
State v. Upton, 127 Idaho 274, 899 P.2d 984 (1995) (revocation inquiry focuses on rehabilitation and public protection)
State v. Marks, 116 Idaho 976, 783 P.2d 315 (1989) (court may reduce sentence or order execution after violation)
State v. Morgan, 153 Idaho 618, 288 P.3d 835 (2012) (review centers on record elements relevant to revocation)