Idaho v. Young

In a consolidated appeal from Ada and Blaine County district court, the issue before the Idaho Supreme Court centered on credit for time served under Idaho Code section 18-309. Marco Antonio Rios-Lopez and Corey Dale Young (collectively, Appellants) sought credit for time served under the construction of section 18- 309, pronounced in Idaho v. Owens, 343 P.3d 30 (2015). The district courts denied Appellants’ motions, and the Court of Appeals affirmed. The district courts in both cases held that Appellants were not entitled to relief under Owens because their judgments of conviction had become final before Appellants filed their Rule 35 motions. Appellants do not contend they were sentenced incorrectly under Idaho v. Hoch, 630 P.2d 143 (1981). Rather, they sought relief under Owens, where, nearly 34 years after Hoch, the Idaho Supreme Court pronounced a different construction of section 18-309 and overruled Hoch. The Supreme Court expressed the construction of section 18-309 pronounced in Owens would apply “only prospectively and to cases now on [i.e., as of February 9, 2015] direct review.” Since Appellants’ judgments of conviction were final before Owens was decided, Appellants were not entitled to relief under Owens. View "Idaho v. Young" on Justia Law