State v. Urrabazo, 150 Idaho 158

Urrabazo pleaded guilty on August 8, 2005 to statutory rape, felony battery on a police officer, and misdemeanor battery; cases were consolidated for sentencing.
On November 7, 2005, the district court imposed a unified 10-year sentence with 3 years fixed for statutory rape and a concurrent 5-year sentence with 3 months fixed for felony battery, retaining jurisdiction for 180 days.
A May 1–5, 2005/2006 hearing considered progress; court contemplated possible relinquishment but granted a Rule 35 motion for a second period of retained jurisdiction instead of probation.
A second 180-day period of retained jurisdiction was ordered, following defense suggestion and continued concerns about rehabilitation and risk, including anger management and substance-abuse treatment.
On July 28, 2006, the court relinquished jurisdiction on the second rider; Urrabazo filed a timely notice of appeal on September 8, 2006, arguing the second rider was improper and sentencing excessive.
The Idaho Supreme Court dismissed the appeal as untimely, holding that the district court violated I.C. § 19-2601(4) by requiring an intervening period of probation before a second retained-jurisdiction period and that the orders were void for lack of subject-matter jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 19-2601(4) requires an intervening probation period before a second retained-jurisdiction period.	Urrabazo argues statute is ambiguous and allows consecutive riders without probation.	Urrabazo contends plain language permits second rider with or without probation as an example.	Statute requires probation before a second rider.
Whether the district court lacked subject-matter jurisdiction to order the second rider.	Because second rider was ordered, jurisdiction existed to entertain appeal.	Orders granting and revoking the second rider exceeded statutory authority.	District court had no jurisdiction; second rider orders were void.

State v. Doe, 147 Idaho 326 (2009) (statutory interpretation framework and plain meaning analysis)
State v. Diggie, 140 Idaho 238 (2004) (retained jurisdiction and probation framework)
State v. Taylor, 142 Idaho 30 (2005) (executive vs. judicial control of jurisdiction during retained periods)
Bach v. Miller, 144 Idaho 142 (2007) (subject-matter jurisdiction and appellate standards)
Sierra Life Ins. Co. v. Granata, 99 Idaho 624 (1978) (judgments without subject-matter jurisdiction are void)