State v. Salsgiver

Two of the most prominent features in Idaho’s felony sentencing scheme are retained jurisdiction under I.C. § 19-2601(4) and reduction of sentence under Rule 35, I.C.R. Jurisdiction may be retained for up to 180 days, while a sentence may be reduced within 120 days after it is imposed. Today we address an issue involving these chronological relationships. We are asked to decide whether the time periods may be aggregated, enabling a defendant to seek Rule 35 relief within 120 days after the court has relinquished jurisdiction previously retained for up to 180 days. For reasons explained below,…