State of Idaho, Plaintiff-Respondent v. Hector B. Almaraz, Jr., Defendant-Appellant (Idaho 2013)

Summary

The Idaho Supreme Court vacated Hector Almaraz’s first‑degree murder conviction and remanded for a new trial, holding that the trial court erred by admitting a suggestive eyewitness identification and by improperly limiting expert testimony on police interview suggestiveness, while affirming the admissibility of gang‑character evidence, Lieutenant Steele’s video testimony, and the video‑expert’s opinion. Justice W. Jones dissented, arguing the errors were harmless and the conviction should stand.

Holding

Whether the district court abused its discretion by admitting gang‑character evidence.. The district court did not abuse its discretion; the evidence was admissible under I.R.E. 404(b) to prove motive and was not substantially outweighed by prejudice.

Whether the district court erred in failing to suppress Hust’s eyewitness identification.. The district court abused its discretion; the identification procedure was overly suggestive and the suggestiveness was not outweighed by reliability factors, so the identification must be suppressed.

Whether the district court abused its discretion by limiting Dr. Reisberg’s expert testimony on the suggestiveness of the police interview.. The district court abused its discretion; the expert may testify about specific suggestive police procedures without invading the jury’s province.

Whether the district court abused its discretion by admitting Lieutenant Steele’s testimony describing Almaraz’s stance as a “shooter’s crouch.”. The district court did not abuse its discretion; the lay opinion was within the trial court’s broad discretion and was subject to a limiting instruction.

Whether the district court abused its discretion in admitting Grant Fredericks’s video‑expert testimony regarding the moment Flores was shot.. The district court did not abuse its discretion; the expert was properly qualified and laid a sufficient foundation to assist the jury.

State of Idaho, Plaintiff-Respondent v. Hector B. Almaraz, Jr., Defendant-Appellant

Summary

Holding

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