State v. Bauer, 51262

Wayne Allen Bauer was convicted of domestic violence with traumatic injury after an altercation with his girlfriend.
Bauer was also charged with attempted strangulation, but the jury could not reach a verdict on that count.
During trial, Bauer attempted to introduce evidence of the victim’s alleged violent character and prior bad acts to support his self-defense claim.
The district court excluded evidence of the victim’s prior bad acts and a past misdemeanor, finding them inadmissible under Idaho Rules of Evidence.
The emergency room physician testified regarding the victim’s injuries and treatment based on a specialist’s recommendations, over Bauer’s hearsay objection.
The prosecution was allowed to impeach Bauer’s claimed peaceful character by referencing his statements to law enforcement about past violent conduct.

Issue	Bauer's Argument	State's Argument	Held
Exclusion of victim’s prior bad acts	Evidence showed victim’s violent character; relevant to self-defense	Irrelevant, prejudicial, improper character evidence	Exclusion upheld
Hearsay objection to ER physician	Physician’s testimony about specialist's recommendations was hearsay	No hearsay; physician didn’t repeat out-of-court statement by specialist	Overruled; testimony admissible
Impeachment by prior bad acts	State’s questioning was improper character evidence	Bauer opened the door by claiming peaceful nature	Permitted; Bauer put peaceable character at issue
Cumulative error	Multiple errors justified reversal	No errors occurred	Doctrine doesn’t apply; no reversal

State v. Custodio, 136 Idaho 197 (Ct. App. 2001) (victim’s violent character alone does not prove self-defense or initial aggression)
State v. Mace, 133 Idaho 903 (Ct. App. 2000) (impeachment with prior acts allowed when defendant testifies about character)
State v. Ehrlick, 158 Idaho 900 (2015) (abuse of discretion standard for evidentiary decisions)