Idaho v. Scraggins, Jr.Annotate this Case
Defendant Abraham Scraggins appealed two district court orders revoking his probation. Defendant was convicted of sexual battery of a minor in 1993, which required that he register as a sex offender in Idaho. In 2009, the State charged him with failure to register when he moved to Ada County in 2008. Defendant pled guilty and received a unified sentence of ten years, five of which were fixed. The sentence was suspended, and Defendant was placed on probation. Under the terms of his probation, Defendant was to serve time in jail at his probation officer's discretion without prior approval of the court. A month after sentencing, the State moved to revoke Defendant's probation, alleging he violated the terms of probation by drinking alcohol and failing to stay at his registered address for a nine-day period. Later in 2009, the State charged Defendant again with failing to register as a sex offender. In a plea agreement, Defendant admitted to violating the terms of his first probation, and pled guilty to failing to register in the second case. The district court revoked Defendant's probation in the first case, and imposed a unified ten-year sentence, with five and one-half years fixed. Less than two months later, probation officers performing a "residence check" found Defendant had contacted his victim, and that he had consumed alcohol. In lieu of filing a report of violation of his probation, Defendant served ten days of the discretionary jail time previously authorized by the district court. At a disposition hearing, Defendant objected to the district court revoking his probation based on these last violations. He argued that because he "had been punished already for this exact same conduct" by serving discretionary jail time, and because "there [was] no new conduct that he has been found in violation for," that a revocation of probation would be a violation of his due process rights. The district court rejected this argument, and accordingly revoked his probation in both cases. It then ordered that the sentences in both cases be executed. Defendant appealed to the Supreme Court, which consolidated the cases on appeal. Upon review, the Court concluded that nothing the probation officers or district court did "affected any articulable due process right." Accordingly, the Court affirmed the district court's decision to revoke Defendant's probation.