Idaho Code

Idaho Code § 18-308 (2026)

Successive terms of imprisonment. 

✓ current as of May 2026
Find cases: SyfertCases citing this section IClegislature.idaho.gov Justiaon Justia CornellLII Search CasesGoogle Scholar

Successive terms of imprisonment. 

When any person is convicted of two (2) or more crimes before sentence has been pronounced upon him for either, the imprisonment to which he is sentenced upon the second or other subsequent conviction, in the discretion of the court, may commence at the termination of the first term of imprisonment to which he shall be adjudged, or at the termination of the second or other subsequent term of imprisonment, as the case may be.

Notes of Decisions
Cited in 66 cases (4 in the last 5 years), 1968–2025 · leading case: State v. Dameniel Preston Owens, 343 P.3d 30 (Idaho 2015).
State v. Dameniel Preston Owens, 343 P.3d 30 (Idaho 2015). · cites it 40× “3d 782, 784 (2004), as follows: Idaho Code § 18-308 is not the source of a court’s authority to impose a cumulative sentence.”
State v. Lawrence, 565 P.2d 989 (Idaho 1977). · cites it 25× “The defendant bases his argument on I.C. § 18-308, as amended in 1972, which reads: “18-308.”
State v. Murillo, 25 P.3d 124 (Idaho Ct. App. 2001). · cites it 18× “Idaho Code Section 18-308 pi’ovides: When any person is convicted of two (2) or more crimes before sentence has been pronounced upon him for either, the imprisonment to which he is sentenced upon the second or other subsequent conviction, in the discretion of the court, may…”
Oregon v. Ice, 555 U.S. 160 (2009). · cites it 2× “§ 53a-37 (2005)); Idaho ( Idaho Code § 18-308 (Lexis 2004)); Nebraska (Neb.”
State v. Mendenhall, 679 P.2d 665 (Idaho Ct. App. 1984). · cites it 12× “In contrast, when reenacting the rest of the prior criminal code, the legislature modified I.C. § 18-308, which had made successive terms of imprisonment for felonies other than escape mandatory in some circumstances.”
State v. Calley, 99 P.3d 616 (Idaho 2004). · cites it 9× “In holding that the district court lacked such authority, the Court of Appeals stated that under Idaho Code § 18-308 , “a sentence of imprisonment can be made to run consecutive only to an earlier term of imprisonment.”
State v. Cisneros-Gonzalez, 112 P.3d 782 (Idaho 2004). · cites it 9× “In holding that the district court *496 lacked such authority, the Court of Appeals stated that under Idaho Code § 18-308 , “a sentence of imprisonment can be made to run consecutive only to an earlier term of imprisonment.”
State v. Chauncey, 554 P.2d 934 (Idaho 1976). · cites it 12× “I.C. § 18-308 provides that: “When any person is convicted of two or more crimes before sentence has been pronounced upon *757 him for either * * * ” then the sentence for the second may be ordered to run consecutively with the first.”
State v. Horejs, 141 P.3d 1129 (Idaho Ct. App. 2006). · cites it 10× “Horejs acknowledges that I.C. § 18-308 authorizes imposition of consecutive terms of incarceration, but argues that this does not provide explicit authority to run misdemeanor sentences consecutive to felony sentences.”
State v. Alberts, 824 P.2d 135 (Idaho Ct. App. 1991). · cites it 8× “I.C. § 18-308; State v. Lawrence, 98 Idaho 399 , 565 P.”
State v. Wagenius, 581 P.2d 319 (Idaho 1978). · cites it 4× “2d 934 (1976), we held that for purposes of I.C. § 18-308, which provides for consecutive sentences "[w]hen any person is convicted of two (2) or more crimes before sentence has been imposed upon him for either .”
State v. Brandt, 715 P.2d 1011 (Idaho Ct. App. 1986). · cites it 5× “2d 934 (1976) the court determined that for purposes of I.C. § 18-308, dealing with the judge’s authority to order consecutive sentences, conviction occurs when a guilty plea is made and the court accepts that plea.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.