State of Idaho v. Sean Saldatore Hurst

── State of Idaho v. Sean Saldatore Hurst ── Court: Idaho Court of Appeals Date: April 30, 2026 Category: General 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51830 STATE OF IDAHO, ) ) Filed: April 30, 2026 Plaintiff-Respondent, ) ) Melanie Gagnepain, Clerk v. ) ) THIS IS AN UNPUBLISHED MARK WAYNE WARNER, ) OPINION AND SHALL NOT ) BE CITED AS AUTHORITY Defendant-Appellant.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 agr