People v. Heintz

Defendant was found guilty of aggravated domestic battery, unlawful restraint, and domestic battery and he was sentenced to three years in prison. The appellate court vacated defendant’s convictions and remanded for a new trial and the supreme court granted the State’s petition for leave to appeal. The supreme court considered whether evidence of the victim’s alleged violent conduct that post-dated the charged offenses was admissible under IRE 405(b)(2) and whether the circuit court abused its discretion in barring evidence that defendant was acquitted of one of four prior alleged acts of domestic violence against the victim. The supreme court reversed the appellate court’s judgment, finding that the trial court properly barred evidence of the victim’s alleged subsequent conduct and that while the trial court erred when it barred the acquittal evidence, that error was harmless because there was no reasonable probability that the jury would have acquitted defendant had the evidence been admitted. (OVERSTREET, HOLDER WHITE, and ROCHFORD, concurring and O’BRIEN, NEVILLE, and CUNNINGHAM, specially concurring)