State v. Sonny Charles Rome, 368 P.3d 660

Rome was convicted for aiding and abetting burglary; district court denied motion to dismiss the burglary statute as unconstitutional; statute applies to entering a place with intent to commit theft or felony; persistent violator enhancement added due to four prior felonies; Rome challenged the statute and the enhancement; court sentenced Rome to 12 years with 4 years determinate on the verdict.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is Idaho § 18-1401 unconstitutional on equal protection grounds?	Rome argues irrational punishment for entering enclosed space.	Rome argues classifications create unequal treatment.	Equal protection challenge rejected.
Does Idaho § 18-1401 violate the First Amendment?	Statute criminalizes thought and chills speech.	Criminalizes act with specific intent, not speech.	First Amendment challenge rejected.
Whether the persistent violator enhancement applies given Rome's prior felonies were separate offenses	State argues statute applies due to four prior felonies.	Claims prior felonies were part of a single scheme; should count as one.	Convictions treated as separate; enhancement proper.
Whether the district court properly denied acquittal on the persistent violator issue	N/A	N/A	District court did not err; enhancement applied.

Rawlings v. State, 159 Idaho 498 (2015) (equal protection and broadened burglary scope; shoplifting costs justify statute)
State v. Brandt, 110 Idaho 341 (1986) (convictions on same day may count as single or multiple depending on context)
State v. Harrington, 133 Idaho 563 (1999) (two Arkansas convictions part of a common scheme treated as one prior conviction)
State v. Saviers, 156 Idaho 324 (2014) (due process/fundamental fairness context in rehabilitative considerations (discussion only))
State v. Hamlin, 156 Idaho 307 (2014) (statutory interpretation of who is punishable under burglary provisions)