State v. Trent Christopher Matney
Background
- Trent Christopher Matney pleaded guilty to injury to a child (I.C. § 18-1501(1)) and to possession of a controlled substance (I.C. § 37-2732(c)(1)).
- District court imposed concurrent unified six-year sentences (three years determinate), suspended those sentences, and placed Matney on probation after a period of retained jurisdiction.
- Matney admitted violating probation in the injury-to-a-child case; the court revoked probation, ordered execution of the sentence, but retained jurisdiction.
- In the drug case, after retained jurisdiction the court again suspended the sentence and placed Matney on probation; Matney later admitted a probation violation and the court revoked probation and executed the underlying sentence.
- Matney appealed, arguing the district court abused its discretion in revoking probation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused its discretion in revoking probation | Matney contends revocation was an abuse of discretion | Court argues revocation is permitted when probation terms are violated and court must weigh rehabilitation and public protection | Court affirmed: no abuse of discretion in revoking probation |
Key Cases Cited
- State v. Beckett, 122 Idaho 324 (Ct. App. 1992) (trial court may revoke probation if terms violated; may order execution or reduce sentence)
- State v. Adams, 115 Idaho 1053 (Ct. App. 1989) (probation revocation within trial court discretion)
- State v. Hass, 114 Idaho 554 (Ct. App. 1988) (probation revocation standards and discretion)
- State v. Upton, 127 Idaho 274 (Ct. App. 1995) (court must consider rehabilitation and protection of society when deciding revocation)
- State v. Marks, 116 Idaho 976 (Ct. App. 1989) (court may reduce sentence under I.C.R. 35 after violation)
- State v. Morgan, 153 Idaho 618 (Ct. App. 2012) (focus of review is the conduct underlying the revocation decision)