Idaho v. BurkeAnnotate this Case
Prior to sentencing, defendant James Burke was committed to the state mental hospital for 56 days to restore him to competency. After being evaluated and deemed competent to proceed to trial, Burke was returned to the county jail and later pleaded guilty pursuant to a plea agreement. At the conclusion of his sentencing hearing, Burke sought credit for the 56 days of time spent in court-ordered commitment. The district court denied the motion, concluding that commitment to a state mental hospital did not fall under the definition of ‘incarceration’ in Idaho Code section 18-309. After reviewing this issue carefully, the Idaho Supreme Court disagreed with the district court’s "thorough and thoughtful analysis," holding that court-ordered commitment to state custody pursuant to Idaho Code sections 18-210 and 18-211 met the functional and legal definition of “incarceration” under Idaho Code section 18-309. "The extent of the liberty interests restricted by Burke’s court-ordered commitment to State Hospital North are just too similar to imprisonment to conclude otherwise." Accordingly, the Court reversed the district court’s order denying Burke’s request for credit for time served and remanded the case for the district court to enter an order crediting him with the fifty-six days he spent committed to State Hospital North while the State restored his competency to face criminal charges.