State v. Escobedo, 50157

Gregory Escobedo was convicted by a jury of aggravated battery (with a deadly weapon enhancement), unlawful possession of a firearm by a felon, grand theft, and being a persistent violator, after shooting a man (E.N.) who confronted him after a vehicle theft.
During police questioning, Escobedo admitted to shooting E.N., stating he did so out of fear, claiming he believed E.N. was associated with a cartel.
At trial, Escobedo sought to have the full context of his confession introduced (including his basis for fear), but the court admitted only the part where he expressed fear, not the cartel-specific rationale.
Escobedo also attempted to exclude detailed evidence of E.N.’s medical injuries, arguing it was irrelevant and prejudicial beyond the basic fact of a gunshot wound, but the court admitted it in part.
He objected to the surgeon testifying about the injuries and bullet extraction, claiming it was cumulative to other testimony (from an officer who witnessed the surgery distantly), but the objection was overruled.
On appeal, Escobedo challenged these evidentiary rulings and argued cumulative error.

Issue	Escobedo's Argument	State's Argument	Held
Admission under I.R.E. 106	The full context of his confession, including his belief E.N. was in a cartel, should be admitted for fairness and to clarify his mental state.	Context statements must be non-hearsay or fit a hearsay exception; only the expression of fear (not the reason) qualifies.	No abuse of discretion in excluding the 'cartel' statement; fear alone admitted was sufficient.
Relevance/prejudice of injury evidence	Extensive details about E.N.'s injuries were irrelevant and prejudicial as they went beyond proving use of a deadly weapon.	Injury evidence was part of proving force/violence and not unduly prejudicial.	The evidence was relevant and not unfairly prejudicial; court's limitation was proper.
Cumulative medical testimony	Testimony from the surgeon was repetitive and prejudicial after already hearing from an officer about the surgery.	The surgeon's testimony was necessary for chain of custody and direct medical evidence; not cumulative.	No error in allowing the surgeon's testimony; it was not cumulative.
Cumulative error	Separate harmless errors together denied him a fair trial.	No or only one error present; cumulative error doctrine doesn’t apply.	No multiple errors found; cumulative error doctrine not triggered.

State v. Joy, 155 Idaho 1 (Idaho 2013) (interpreting scope of Idaho Rule of Evidence 106—context evidence must be relevant to what was introduced)
State v. Garcia, 166 Idaho 661 (Idaho 2020) (defining legal relevance and admissibility of evidence to a material issue)
State v. Adamcik, 152 Idaho 445 (Idaho 2012) (articulating cumulative error doctrine requirements)
State v. Fordyce, 151 Idaho 868 (Idaho Ct. App. 2011) (describing unfair prejudice analysis for evidence integral to the charged crime)
State v. Johnson, 148 Idaho 664 (Idaho 2010) (materiality determination based on legal theories at issue)