State of Idaho v. Sean Saldatore Hurst

CourtIdaho Court of Appeals
DecidedApril 30, 2026
Docket52463
StatusUnpublished

This text of State of Idaho v. Sean Saldatore Hurst (State of Idaho v. Sean Saldatore Hurst) is published on Counsel Stack Legal Research, covering Idaho Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Idaho v. Sean Saldatore Hurst, (Idaho Ct. App. 2026).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF IDAHO

Docket No. 51830

STATE OF IDAHO, ) ) Filed: April 30, 2026 Plaintiff-Respondent, ) ) Melanie Gagnepain, Clerk v. ) ) THIS IS AN UNPUBLISHED MARK WAYNE WARNER, ) OPINION AND SHALL NOT ) BE CITED AS AUTHORITY Defendant-Appellant. ) )

Appeal from the District Court of the Third Judicial District, State of Idaho, Owyhee County. Hon. Randall S. Grove and Hon. Thomas W. Whitney, District Judges.

Amended order relinquishing jurisdiction, affirmed.

Erik R. Lehtinen, State Appellate Public Defender; Sally J. Cooley, Deputy Appellate Public Defender, Boise, for appellant.

Hon. Raúl R. Labrador, Attorney General; Michael MacEgan, Deputy Attorney General, Boise, for respondent. ________________________________________________ TRIBE, Chief Judge Mark Wayne Warner appeals from the district court’s amended order relinquishing jurisdiction. For the reasons set forth below, we affirm. I. FACTUAL AND PROCEDURAL BACKGROUND The State charged Warner with involuntary manslaughter, aggravated battery, aggravated assault and malicious injury to property and alleged that he is a persistent violator of the law. Pursuant to an Idaho Criminal Rule 11 plea agreement, Warner agreed to plead guilty to aggravated battery (Idaho Code § 18-907) and aggravated assault (I.C. § 18-905) and to admit to being a persistent violator of the law (I.C. § 19-2514). In exchange for his guilty pleas, the State agreed to dismiss the remaining charges and for Warner to be bound by a life sentence (with five years determinate) subject to a period of retained jurisdiction (rider) followed by probation if he

1 “successfully complete[d]” his rider. The plea agreement did not define successful completion of the rider. At sentencing, the district court accepted the binding I.C.R. 11 plea agreement and imposed concurrent unified sentences of life in prison, with minimum periods of confinement of five years, and retained jurisdiction. The Idaho Department of Correction (IDOC) later filed an addendum to Warner’s presentence investigation report (APSI), recommending the district court consider placing Warner on probation. After Warner completed the rider program during the period of retained jurisdiction, the district court held a review hearing. After considering the IDOC’s recommendation and the factors set forth in I.C. § 19-2521, the district court relinquished jurisdiction. Warner did not file a direct appeal from the order relinquishing jurisdiction; however, Warner filed a post-conviction action, asking the district court (in part) to reinstate his right to appeal from the order relinquishing jurisdiction. After concluding that Warner was denied the effective assistance of counsel as a result of trial counsel’s failure to file a direct appeal, the district court entered an amended order relinquishing jurisdiction. Warner timely appeals from the amended order relinquishing jurisdiction. II. STANDARD OF REVIEW Whether a plea agreement has been breached is a question of law to be reviewed by this Court de novo, in accordance with contract law standards. State v. Jafek, 141 Idaho 71, 73, 106 P.3d 397, 399 (2005). As with other types of contracts, “the interpretation of a plea agreement and its legal effect are questions of law to be decided by the Court if the terms are clear and unambiguous.” State v. Lutes, 141 Idaho 911, 914, 120 P.3d 299, 302 (Ct. App. 2005). The determination that a plea agreement is ambiguous is a question of law; however, interpretation of an ambiguous term is a question of fact. State v. Peterson, 148 Idaho 593, 595, 226 P.3d 535, 537 (2010). A trial court’s factual determinations shall not be set aside on review unless they are clearly erroneous. Id. The decision to place a defendant on probation or whether, instead, to relinquish jurisdiction over the defendant is a matter within the sound discretion of the district court and will not be overturned on appeal absent an abuse of that discretion. State v. Hood, 102 Idaho 711, 712, 639 P.2d 9, 10 (1981); State v. Lee, 117 Idaho 203, 205-06, 786 P.2d 594, 596-97 (Ct. App. 1990).

2 When a trial court’s discretionary decision is reviewed on appeal, the appellate court conducts a multi-tiered inquiry to determine whether the trial court: (1) correctly perceived the issue as one of discretion; (2) acted within the boundaries of such discretion; (3) acted consistently with any legal standards applicable to the specific choices before it; and (4) reached its decision by an exercise of reason. State v. Herrera, 164 Idaho 261, 270, 429 P.3d 149, 158 (2018). III. ANALYSIS A. Breach of Plea Agreement Warner contends the district court breached the binding plea agreement by not placing him on probation following his rider. More specifically, Warner asserts the breach occurred when the district court relinquished jurisdiction rather than placing him on probation because, he argues, pursuant to the terms of the binding plea agreement, the IDOC’s recommendation for probation constituted successful completion of his rider. The State responds, and Warner concedes, that the claimed breach must be evaluated under the fundamental error framework because the issue is not preserved. Under this framework, the State argues that Warner has failed to meet his burden of showing fundamental error. We hold that Warner has failed to show a constitutional violation entitling him to relief under the fundamental error doctrine. In order to obtain relief under the fundamental error doctrine, the defendant must demonstrate three things. First, the defendant must show that one or more of the defendant’s unwaived constitutional rights were violated. State v. Miller, 165 Idaho 115, 119, 443 P.3d 129, 133 (2019). Second, the error must be clear and obvious, meaning the record must demonstrate evidence of the error and evidence as to whether or not trial counsel made a tactical decision in failing to object. Id. Third, the defendant must demonstrate that the error affected the defendant’s substantial rights, which means the error identified in the first and second prongs of the test actually affected the outcome of the trial. Id. at 119-20, 443 P.3d at 133-34. Warner’s claim fails under the first prong of the fundamental error analysis. Warner argues that the district court violated the I.C.R. 11 binding plea agreement because the IDOC’s probation recommendation demonstrated he successfully completed his rider, which in turn obligated the district court to place him on probation. We disagree.

3 When a trial court accepts a plea agreement, it agrees to be “bound by the terms of the plea agreement in the final disposition of the case.” I.C.R. 11(f)(3). When a plea agreement makes a particular disposition contingent upon a specified event, the provision operates as a condition precedent. A condition precedent is an event that must occur before performance under a contract becomes due. Med. Recovery Servs., LLC v. Melanese, 175 Idaho 81, 90, 562 P.3d 182, 191 (2024). Both the express and implied terms of the plea agreement must be considered by the trial court. Lutes, 141 Idaho at 914, 120 P.3d at 302.

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Related

Puckett v. United States
556 U.S. 129 (Supreme Court, 2009)
State v. Peterson
226 P.3d 535 (Idaho Supreme Court, 2010)
State v. Hood
639 P.2d 9 (Idaho Supreme Court, 1981)
State v. Jafek
106 P.3d 397 (Idaho Supreme Court, 2005)
State v. Lee
786 P.2d 594 (Idaho Court of Appeals, 1990)
State v. Coassolo
30 P.3d 293 (Idaho Supreme Court, 2001)
State v. Lutes
120 P.3d 299 (Idaho Court of Appeals, 2005)
State v. Herrera
429 P.3d 149 (Idaho Supreme Court, 2018)
State v. Miller
443 P.3d 129 (Idaho Supreme Court, 2019)

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Bluebook (online)
State of Idaho v. Sean Saldatore Hurst, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-idaho-v-sean-saldatore-hurst-idahoctapp-2026.