State v. Robert Antonelli Steady, Jr.
Background
- Robert Antonelli Steady Jr. pleaded guilty to grand theft in 2013; received a unified 7-year sentence with 4-year minimum, suspended in favor of probation.
- In 2014 Steady entered an Alford plea to grand theft, received a concurrent unified 9-year sentence with 4-year minimum; he admitted probation violation from the 2013 case, the court revoked then re-suspended and regranted probation.
- In 2015 Steady pleaded guilty to three counts of burglary and received concurrent unified 10-year sentences with 5-year minimums, concurrent with earlier sentences; he admitted violating probation in the 2013 and 2014 cases.
- The district court revoked probation and ordered execution of the previously suspended sentences; Steady’s I.C.R. 35 motions to reduce sentences were denied.
- On appeal Steady did not contest the revocations but argued the district court abused its discretion by not retaining jurisdiction (for the 2013/2014 and 2015 matters) and that the 2015 burglary sentences were excessive.
- The Idaho Court of Appeals reviewed sentencing and jurisdiction principles and affirmed the convictions and sentences, holding no abuse of discretion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court should have retained jurisdiction after sentencing (2013/2014 grand thefts) | Steady: court should have retained jurisdiction to further evaluate rehabilitation potential | State: trial court properly exercised discretion not to retain jurisdiction | Court: no abuse of discretion; affirmed denial of retained jurisdiction |
| Whether the district court should have retained jurisdiction after sentencing (2015 burglaries) | Steady: court should have retained jurisdiction for rehabilitation review | State: trial court discretionary decision was proper | Court: no abuse of discretion; affirmed denial of retained jurisdiction |
| Whether the 2015 burglary sentences are excessive | Steady: sentences (concurrent 10-year unified terms, 5-year minimums) are overly harsh | State: sentences are within statutory range and aimed at protection/deterrence; trial court considered relevant factors | Court: independent review found no excessive sentence; affirmed |
Key Cases Cited
- State v. Hernandez, 121 Idaho 114, 822 P.2d 1011 (Ct. App.) (sentencing is within trial court discretion)
- State v. Toohill, 103 Idaho 565, 650 P.2d 707 (Ct. App.) (confinement reasonable when necessary for protection, deterrence, rehabilitation, retribution)
- State v. Oliver, 144 Idaho 722, 170 P.3d 387 (Ct. App.) (review of aggregate sentence considers the defendant’s entire sentence)
- State v. Hanington, 148 Idaho 26, 218 P.3d 5 (Ct. App.) (review of executed sentence after probation revocation examines record before and after original judgment)
- State v. Atwood, 122 Idaho 199, 832 P.2d 1134 (Ct. App.) (retention of jurisdiction is within trial court discretion to evaluate rehabilitation potential)