State v. Coleman, 276 P.3d 744

Coleman was charged with sexual abuse of a child under sixteen for exposing his penis to a seven-year-old girl.
The incident involved the junkyard encounter, sexual comments, touching of the child’s vaginal area, and public urination with exposure.
Before trial, State sought to admit Rule 404(b) evidence of two grooming-related prior incidents: pants incident and bonfire incident.
Coleman moved to exclude Rule 404(b) evidence and related grooming expert testimony; district court reserved ruling and later admitted the pants incident but未 ruled on bonfire.
Trial proceeded; jury convicted Coleman; district court imposed a unified sentence of fifteen years with seven years determinate.
Coleman timely appealed the admission of Rule 404(b) evidence and related issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rule 404(b) evidence was relevant to Coleman’s charged conduct	State argues the prior acts show grooming pattern relevant to intent/plan	Coleman contends the acts are not part of a grooming pattern and are not probative of intent	No; prior acts fail to show a grooming pattern or plan toward the charged offense.
Whether district court properly weighed probative value against unfair prejudice	State contends court balanced probative value and prejudice	Coleman argues improper or limited balancing and potential prejudice overruns probative value	No; court abused its discretion in balancing and admitting the evidence.
Whether the Rule 404(b) error was harmless	State asserts limited prejudice due to other strong evidence	Coleman asserts prejudice from other acts evidence could have affected guilt	Not harmless; error reversible; remand for further proceedings.

State v. Grist, 147 Idaho 49, 205 P.3d 1185 (Idaho Supreme Court 2009) (grooming evidence must show plan or motive beyond propensity)
State v. Blackstead, 126 Idaho 14, 878 P.2d 188 (Idaho Ct. App. 1994) (grooming evidence may be admissible when part of a continuing design to molest)
State v. Truman, 150 Idaho 714, 249 P.3d 1169 (Idaho Ct. App. 2010) (grooming evidence admissible to show continuing criminal design to cultivate relationship)
State v. Alvord, 47 Idaho 162, 272 P.1010 (Idaho Supreme Court 1928) (proof of plan to commit charged crime admissible under grooming theory)
State v. Parmer, 147 Idaho 210, 207 P.3d 186 (Ct. App. 2009) (deference to trial court on sufficiency of prior-act evidence; abuse of discretion standard for balancing)
State v. Norton, 151 Idaho 176, 254 P.3d 77 (Ct. App. 2011) (standard for reviewing Rule 404(b) balancing is abuse of discretion)
State v. Stoddard, 105 Idaho 169, 667 P.2d 272 (Ct. App. 1983) (harmless-error framework for non-constitutional error)
State v. Pokorney, 149 Idaho 459, 235 P.3d 409 (Ct. App. 2010) (limiting instruction does not guarantee the absence of prejudice from prior-act evidence)
Johnson, 148 Idaho 670, 227 P.3d 924 (Ct. App. 2010) (prior misconduct evidence inherently prejudicial in sexual offense cases)