Idaho v. Thiel
Annotate this CaseIn 2011, Corey Thiel was charged with felony domestic battery. Pursuant to a plea agreement, Thiel pled guilty to an amended charge of misdemeanor domestic battery and was placed on supervised probation. Approximately one week after entry of this guilty plea, Thiel was charged with a misdemeanor violation of a no-contact order for an incident that occurred while the battery charge was pending. Thiel pled guilty to violating the no-contact order, and the magistrate court imposed suspended jail time and two years of unsupervised probation, while crediting time served. Under the terms of his probation, Thiel was required to comply with the terms of supervised probation established in the underlying battery case. Less than two months thereafter, on May 2, 2012, the State moved for the court to issue a bench warrant for Thiel’s arrest based on probation violations. At a hearing on the State’s motion, Thiel admitted the violations. The court reinstated Thiel on probation. Approximately four months thereafter, the State moved for a second set of probation violations, alleging that Thiel failed to maintain contact with his assigned probation officer and also failed to provide documentation that he had completed the required domestic violence treatment. At a hearing on the State’s motion, Thiel admitted the violations. The court revoked Thiel’s probation and imposed his original sentence of 356 days, with a credit of 67 days. Fifty-five days before his sentence was to end, the Ada County Sheriff’s Office submitted a letter to the magistrate court recommending that Thiel be granted early release. The magistrate court denied the Sheriff’s request. The issue this case presented for the Supreme Court's review was one of statutory interpretation: Idaho Code section 20-621 authorizes commutation of county jail sentences for good behavior, making county inmates with good records while incarcerated eligible for five (5) days off for each and every month of their sentence. A prisoner’s eligibility, however, was conditioned upon receiving a recommendation from the supervising county sheriff. The primary issue presented here was whether the statute vested the magistrate court with the discretion to reject a recommendation from a sheriff. The Supreme Court affirmed the district court's conclusion that the statute vested no discretion with the magistrate judge.
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