State v. Anthony Edward Ortega, 339 P.3d 1186

Ortega was charged with two counts of felony injury to a child for (1) causing a spiral humerus fracture to his two‑year‑old son A.O., and (2) striking the child’s buttocks, abdomen, and chest.
The State sought to admit prior‑bad‑act evidence of Ortega’s prior harsh discipline toward very young children to rebut his claims that the injuries were accidental.
The district court admitted testimony from family members describing prior incidents (severe spankings, grabbing/jerking arm, holding nose tightly) and medical experts who said the fracture and patterned bruising were inconsistent with ordinary falls or toddler play.
Ortega did not testify; his defense presented witnesses attesting to his good parenting and argued the injuries were accidental or within reasonable parental discipline.
Ortega requested a jury instruction expressly defining "reasonable parenting efforts"; the court refused and instead gave the standard model instruction including a willfulness mens rea definition.
The jury convicted on both counts; Ortega appealed asserting (1) improper admission of prior‑bad‑act evidence under I.R.E. 404(b) and (2) erroneous refusal to give the requested parenting instruction. The Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of prior‑bad‑act evidence under I.R.E. 404(b)	State: evidence admissible to show absence of mistake/accident or intent, rebutting Ortega's accident defense	Ortega: intent not at issue; evidence only shows propensity and is unfairly prejudicial	Court: admissible — intent/absence of mistake were contested; alternative permissible inference existed; probative value > prejudice
Necessity of a separate "reasonable parenting efforts" jury instruction	State: standard mens rea instruction adequately informs jury that reasonable parenting precludes guilt	Ortega: requested instruction required to inform jury of parenting‑effort defense	Court: refused — defense subsumed in proper willfulness instruction; separate instruction unnecessary

State v. Grist, 147 Idaho 49, 205 P.3d 1185 (discussing 404(b) admissibility framework)
State v. Parmer, 147 Idaho 210, 207 P.3d 186 (prior acts admissible to show absence of mistake/intent when material)
State v. Peters, 116 Idaho 851, 780 P.2d 602 (statute not void for vagueness; mens rea limits reach of injury‑to‑child law)
State v. Young, 138 Idaho 370, 64 P.3d 296 (mens rea instruction must preclude conviction based on good‑faith mistake)