State v. Teddy Edghill Substitute, 317 P.3d 743

In 1997 Edghill pled guilty to vehicular manslaughter after running over a child; he received a unified six-year term (3-year minimum) and a lifetime driver’s license suspension.
The district court retained jurisdiction, later suspended execution, and placed Edghill on probation; the lifetime suspension remained but an amended judgment (1998) stated the court would consider petitions to allow license application after ten years.
Edghill received several limited conditional ATV permits over the years; in 2012 a new judge ruled the ten‑year‑petition provision illegal and struck it but left the lifetime suspension intact.
Edghill filed an I.C.R. 35 motion asserting the driver’s license suspension (and the 2012 modification) was illegal; the district court denied relief.
On appeal this Court evaluated invited‑error and res judicata defenses raised by the State and considered whether the court should have resentenced (with defendant present) rather than excised the illegal provision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Edghill is estopped by invited error from challenging the court’s excision of the ten‑year petition provision	State: error induced by Edghill’s conduct; invited error bars relief	Edghill: the court sua sponte excised the provision; he did not induce the error	Invited‑error does not apply — excision was sua sponte and not induced by Edghill
Whether res judicata bars relitigation of the legality of the lifetime suspension	State: prior appeal decided lifetime suspension lawful, so issue precluded	Edghill: the 2012 modification (striking reinstatement language) raises a distinct, unadjudicated issue	Res judicata bars relitigation of the earlier challenge to a lifetime suspension, but does not bar review of the 2012 modification issue
Proper remedy when a sentencing provision is illegal: severance versus resentencing	State/district court: excise the illegal portion and leave remainder	Edghill: court should have resentenced regarding license suspension with him present and consider the whole suspension	Court: severing the illegal provision was error; district court must hold a resentencing hearing with defendant present and consider the entire license‑suspension scheme, including length

State v. Edghill, 134 Idaho 218, 999 P.2d 255 (Ct. App.) (prior appeal upholding lifetime suspension under statute)
State v. Money, 109 Idaho 757, 710 P.2d 667 (Ct. App.) (when correcting an illegal sentence court may resentence and must consider whole sentence; defendant must be present)
Lopez v. State, 108 Idaho 394, 700 P.2d 16 (Idaho) (ex parte correction of sentencing can deny due process; defendant presence at sentencing required)
United States v. Jordan, 895 F.2d 512 (9th Cir.) (federal view limiting correction to reduction of excess, cited by district court but deemed contrary to Idaho law)
State v. Petersen, 149 Idaho 808, 241 P.3d 981 (Ct. App.) (court’s jurisdiction typically ends once defendant committed to custody)
State v. Rhoades, 134 Idaho 862, 11 P.3d 481 (Idaho) (res judicata principles explained)