State v. Daniel Edward Ehrlick, Jr., 158 Idaho 900

Ehrlick convicted in Ada County for first-degree murder of a child and failure to report a death.
Trial evidence included testimony about credibility of witnesses and the absence of credible sightings on July 24.
A clay/plastic model of R.M.’s head and a sheetrock hole were admitted to support the State’s theory of how injuries occurred.
I.R.E. 404(b) evidence included Ehrlick’s prior girlfriends and his attempts to contact Jenkins to influence testimony.
Burnett testified about a birthday party story; much of this testimony was later found to be hearsay and not admissible, but the error was deemed harmless.
The Supreme Court affirmed Ehrlick’s judgment of conviction, finding several evidentiary errors harmless and upholding other challenged rulings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the district court err admitting credibility opinions by Agent Martin?	Martin’s credibility assessment usurped the jury.	The testimony explained the investigation, not witness credibility.	Yes, error, but harmless.
Was the head model properly admitted as relevant demonstrative evidence?	Model aided jurors in evaluating injuries and location.	Discrepancies in size made it irrelevant.	No reversible error; admissible as probative demonstrative evidence.
Was the I.R.E. 404(b) evidence (former girlfriends, etc.) admissible?	Evidence showed intent to torture/sadistic inclinations.	Evidence was unfairly prejudicial and not sufficiently linked to the charged act.	Admissible; probative value outweighed prejudice.
Was Burnett’s testimony about witnesses’ lack of knowledge of a birthday party hearsay?	Testimony explained why the party story was implausible.	Statements of others to Burnett were hearsay.	Hearsay error; harmless.
Did prosecutorial misconduct occur in closing arguments?	Prosecutor misstated evidence and urged improper theories.	Arguments were fair inferences from the evidence.	No reversible error; cumulative harmless.

State v. Almaraz, 154 Idaho 584 (2013) (limits expert testimony encroaching on jury credibility; Rule 702 guidance)
State v. Perry, 150 Idaho 209 (2010) (harmless-error framework for evidentiary errors)
State v. Stevens, 146 Idaho 139 (2008) (three-part test for admissibility of evidence; relevance and discretion)
State v. Hester, 114 Idaho 688 (1988) (limits expert testimony on witness credibility; jury function)
State v. Grist, 147 Idaho 49 (2009) (404(b) analysis and balancing probative value vs. unfair prejudice)
State v. Joy, 155 Idaho 1 (2013) (two-part 404(b) relevance and prejudice test)
State v. Pokorney, 149 Idaho 459 (Ct. App. 2010) (consciousness of guilt evidence via attempts to influence witnesses)
State v. Sheahan, 139 Idaho 267 (2003) (consciousness of guilt and 404(b) mechanism)
State v. Raudebaugh, 124 Idaho 758 (1993) (closing argument mischaracterization guidance; admissibility context)