Idaho v. Haws
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Darius Haws appealed after he pled guilty to delivery of a controlled substance and battery on a police officer pursuant to plea agreements in which he waived his right to appeal his convictions or sentences. The district court sentenced Haws to two years fixed, with four years indeterminate, for the delivery charge; and one year fixed, with three years indeterminate, for the battery charge. The sentences were ordered to run consecutively. Additionally, the district court retained jurisdiction over Haws. However, after Haws performed poorly during the period of retained jurisdiction, the district court relinquished jurisdiction over Haws and ordered that the original sentences be served by Haws.
Haws appealed, arguing that the district court abused its discretion in relinquishing jurisdiction and that his sentences were excessive. In response, the State sought to have Haws’ appeal dismissed because Haws expressly waived his right to appeal his sentences in the plea agreements he signed. The Court of Appeals dismissed Haws' challenge to his sentences and affirmed the district court's decision to relinquish jurisdiction. Haws appealed to the Idaho Supreme Court, arguing the appellate court erred in finding he forfeited his right to address the validity of his plea agreements. Haws contended that it was the State’s obligation to assert the applicability of the appellate waiver, and that he should have had the opportunity to respond in his reply brief. Additionally, Haws contended his appellate waiver was not made knowingly, intelligently, and voluntarily because the district court made a statement that conflicted with the written plea agreements by noting that Haws had the right to appeal his sentences. Finding no reversible error in the appellate's or trial court's decisions, the Supreme Court affirmed.
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