State v. Sonnie Flores, 162 Idaho 298

In Sept. 2012 Flores pled guilty to felony eluding; judgment entered Jan. 14, 2013 with a 5-year unified sentence (3-year determinate + 2-year indeterminate) suspended and probation imposed.
Probation revoked twice; on Aug. 7, 2015 the court reinstated the sentence but suspended execution for up to 365 days under Idaho Code § 19-2601(4), retaining jurisdiction while Flores was placed with the State Board of Correction at NICI.
NICI filed an addendum to the presentence report documenting misconduct and gang-oriented behavior (unauthorized transfers, associating with assaulting inmates, gang items/drawings, misuse of other inmates’ PINs) and recommended relinquishment of jurisdiction.
The district court relinquished jurisdiction on Dec. 15, 2015 based primarily on NICI’s security-risk classification and recommendations.
Flores moved Dec. 30, 2015 to reinstate jurisdiction (styled as a Rule 35 motion); the district court denied the motion and Flores appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court abused discretion in relinquishing retained jurisdiction	State: NICI’s report supported relinquishment due to security risk and misconduct	Flores: Good progress at NICI showed retained jurisdiction should continue	Court: No abuse of discretion; district court acted within bounds and relied on credible NICI report
Whether court erred by denying motion to reinstate retained jurisdiction / reconsideration	State: Statute and procedure do not allow reinstating jurisdiction after relinquishment; Rule 35 inapplicable	Flores: Court retained jurisdiction for up to 365 days and should be able to reinstate to allow completion of program	Court: Denial affirmed — Rule 35 doesn’t apply; I.C. § 19-2601(4) permits relinquishment during retained period and does not authorize reinstating an additional retained period absent probation first

State v. Latneau, 154 Idaho 165 (discretionary review of relinquishment) (2013)
Swallow v. Emergency Med. of Idaho, P.A., 138 Idaho 589 (discretionary standard and review framework) (2003)
State v. Statton, 136 Idaho 135 (good NICI performance alone doesn’t mandate probation) (2001)
State v. Brunet, 155 Idaho 724 (district court may relinquish during retained period) (2013)
State v. Coassolo, 136 Idaho 138 (same) (2001)
State v. Funk, 123 Idaho 967 (sentencing court limited to authority granted by legislature) (1993)
Hayes v. City of Plummer, 159 Idaho 168 (statutory interpretation reviewed de novo) (2015)
State v. Burnight, 132 Idaho 654 (plain-language statutory interpretation principles) (1999)