State v. Shane Michael Mendenhall
Background
- Defendant Shane Michael Mendenhall convicted of burglary (I.C. § 18-1401) and possession of a controlled substance (I.C. § 37-2732(c)); pleaded guilty to persistent violator enhancement.
- District court sentenced: unified 15-year sentence with 5 years determinate for burglary (with enhancement); unified 1-year indeterminate for possession; sentences concurrent.
- Court retained jurisdiction and sent Mendenhall to retained jurisdiction program, then later relinquished jurisdiction.
- At jurisdictional review, Mendenhall filed an I.C.R. 35 motion seeking reduction of sentence; the court denied the motion.
- Mendenhall appealed, arguing the sentence was excessive, the court erred in relinquishing jurisdiction, and the court should have reduced his sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the overall sentence was excessive | Mendenhall: sentence unreasonable/excessive | State: sentencing within discretion and justified by record | Court: no abuse of discretion; sentence affirmed |
| Whether relinquishing retained jurisdiction was an abuse of discretion | Mendenhall: court should not have relinquished jurisdiction / should have imposed probation | State: decision to relinquish jurisdiction is within trial court discretion | Court: district court properly considered factors; no abuse of discretion |
| Whether denial of I.C.R. 35 motion was erroneous | Mendenhall: presented basis for leniency and sentence reduction | State: I.C.R. 35 requires new/additional information showing excessiveness; none shown | Court: I.C.R. 35 denial was within discretion; no new information; affirmed |
| Whether sentencing pronouncement erred by separately stating persistent violator punishment | Mendenhall: oral pronouncement created separate sentence for enhancement | State: enhancement increases the sentence for the underlying conviction, not a separate sentence | Court: oral separate sentence was error (not before Court as issue), enhancement is a single increased penalty |
Key Cases Cited
- State v. Hernandez, 121 Idaho 114, 822 P.2d 1011 (1991) (standards for reviewing sentence reasonableness)
- State v. Lopez, 106 Idaho 447, 680 P.2d 869 (1984) (factors for evaluating reasonableness of sentence)
- State v. Toohill, 103 Idaho 565, 650 P.2d 707 (1982) (sentencing review principles)
- State v. Oliver, 144 Idaho 722, 170 P.3d 387 (2007) (review of entire sentence length)
- State v. Hood, 102 Idaho 711, 639 P.2d 9 (1981) (probation and jurisdiction discretion)
- State v. Lee, 117 Idaho 203, 786 P.2d 594 (1990) (relinquishing jurisdiction review)
- State v. Knighton, 143 Idaho 318, 144 P.3d 23 (2006) (I.C.R. 35 is plea for leniency committed to court's discretion)
- State v. Allbee, 115 Idaho 845, 771 P.2d 66 (1989) (I.C.R. 35 standards)
- State v. Galaviz, 104 Idaho 328, 658 P.2d 999 (1983) (I.C.R. 35 and sentencing reductions)
- State v. Huffman, 144 Idaho 201, 159 P.3d 838 (2007) (I.C.R. 35 requires new or additional information to show excessiveness)
- Lopez v. State, 108 Idaho 394, 700 P.2d 16 (1985) (persistent violator enhancement increases penalty for conviction, not a separate crime)