State v. William Patrick Berkeley
Background
- William Patrick Berkeley pled guilty to felony DUI in 2008 and received a unified 10-year sentence with 2 years determinate; court retained jurisdiction and later placed him on probation.
- In 2010 he pled guilty to another felony DUI, admitted probation violation in the 2008 case, received a concurrent unified 10-year sentence with 3 years determinate, and the 2008 suspended sentence was executed; court retained jurisdiction and later reinstated probation after the rider.
- In 2012 probation was reinstated after a violation; in 2014 Berkeley pled guilty to meth possession, received a concurrent unified 6-year sentence with 2 years determinate suspended and was placed on probation; probation in the prior DUI cases was reinstated.
- In 2016, pursuant to a plea agreement, Berkeley entered an Alford plea to unlawful possession of a firearm, admitted violating probation in his three prior cases, and was sentenced to a concurrent unified 3-year sentence with 1 year determinate; the court revoked probation in the three prior cases and executed their underlying sentences—resulting in an aggregate 10-year sentence with 3 years determinate.
- Berkeley appealed, arguing the district court abused its discretion in sentencing for the firearm offense and in revoking probation and executing the suspended sentences in his other cases.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused its discretion in sentencing Berkeley for unlawful possession of a firearm | Berkeley contends the sentence was excessive/abusive | State argues sentencing was within trial court discretion and appropriate given record | Court held no abuse of discretion—sentence affirmed |
| Whether the district court abused its discretion in revoking probation in the prior DUI and drug cases | Berkeley argues revocation/execution of suspended sentences was improper | State argues court properly revoked probation based on violations and may execute suspended sentences | Court held revocations and execution of sentences were within discretion and affirmed |
| Whether retained jurisdiction or alternative sentencing should have been used instead of execution | Berkeley asserts alternatives (retained jurisdiction or reduction) were warranted | State emphasizes probation violations and need for protection/rehabilitation justifies execution | Court found district court acted within its discretion; alternatives not required |
| Whether record supported revocation and sentencing review standard | Berkeley challenges sufficiency of record to justify revocation/sentence | State points to probation violations and relevant record before trial court | Court applied established standards and found record supported decisions |
Key Cases Cited
- Beckett v. State, 122 Idaho 324 (Ct. App. 1992) (standards for probation revocation and execution of suspended sentence)
- Adams v. State, 115 Idaho 1053 (Ct. App. 1989) (probation revocation discretion)
- Hass v. State, 114 Idaho 554 (Ct. App. 1988) (probation revocation principles)
- Upton v. State, 127 Idaho 274 (Ct. App. 1995) (rehabilitation and public protection as revocation criteria)
- Marks v. State, 116 Idaho 976 (Ct. App. 1989) (court may reduce or execute suspended sentence after violation)
- Morgan v. State, 153 Idaho 618 (Ct. App. 2012) (focus on conduct in record supporting revocation)
- Hernandez v. State, 121 Idaho 114 (Ct. App. 1991) (standards of appellate review of sentencing)
- Lopez v. State, 106 Idaho 447 (Ct. App. 1984) (factors for evaluating sentence reasonableness)
- Toohill v. State, 103 Idaho 565 (Ct. App. 1982) (sentencing review principles)
- Oliver v. State, 144 Idaho 722 (2007) (consider defendant’s entire sentence on review)
- North Carolina v. Alford, 400 U.S. 25 (1970) (Alford plea doctrine)