State v. Samir Michael Abrams

In 2013, Samir Michael Abrams pleaded guilty to providing false information to the sex-offender registry; judgment entered July 19, 2013, and the district court retained jurisdiction initially.
After completing the retained-jurisdiction period, Abrams was placed on probation; he did not appeal the judgment or the probation order.
On September 2, 2016, Abrams filed an Idaho Criminal Rule 33(c) motion to withdraw his guilty plea, contending there was no factual basis for the plea.
The district court dismissed the Rule 33(c) motion for lack of subject matter jurisdiction.
Abrams appealed; the Court of Appeals reviewed whether the trial court retained jurisdiction to consider a post-final Rule 33(c) motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court had jurisdiction to hear a Rule 33(c) motion filed after the judgment became final	State: Trial court lacked jurisdiction; judgment finality cuts off post-judgment motions unless a statute or rule extends jurisdiction	Abrams: His Rule 33(c) motion challenging factual basis could be heard despite finality	The court held the district court lacked subject matter jurisdiction because the motion was filed after the judgment was final

Boyd v. Steele, 6 Idaho 625 (1899) (trial court jurisdiction does not continue indefinitely)
State v. Jakoski, 139 Idaho 352 (2003) (Rule 33(c) does not extend trial court jurisdiction after judgment becomes final)
State v. Jones, 140 Idaho 755 (2004) (lack of jurisdiction is a question of law reviewable at any time)