State v. Hayes, 462 P.3d 1110

Defendant Michael Hayes, an IMSI inmate, was charged with two counts of felony battery on correctional officers after an altercation on November 10, 2015; jury convicted him of one count (kicking Officer Nettles).
Hayes sought subpoenas for two Corizon medical providers to show post‑altercation injuries (blood in urine); the district court denied the requests as untimely and, alternatively, irrelevant.
Hayes testified in his own defense; on cross‑examination the prosecutor questioned him about prior threats, insults, and disrespect toward officers and inmates. The court allowed the inquiry as bearing on credibility and gave a limiting instruction.
Hayes moved for a new trial arguing the court’s in limine order barring questions on IDOC disciplinary/infraction guidelines prevented impeachment of officers and was erroneous; the district court denied the motion (relevance and I.R.E. 403 grounds).
The Court of Appeals reversed (ordering new trial), but the Idaho Supreme Court granted review and affirmed: it upheld denial of subpoenas (Hayes did not challenge timeliness on appeal) and concluded prior‑acts questioning—though mischaracterized under I.R.E. 608(b)—was admissible as impeachment by contradiction and not unfairly prejudicial; denial of a new trial was also affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Hayes)	Held
1) Denial of subpoenas for medical witnesses	Denial proper because Hayes’ pro se subpoena request was untimely; also argued subpoenas irrelevant	Subpoenas relevant to show injuries caused by officers and support innocence	Affirmed: denial sustained on untimeliness (Hayes did not challenge timeliness on appeal)
2) Admissibility of prior incidents on cross‑examination	Prior incidents were admissible to attack Hayes’ credibility (court may inquire under I.R.E. 608(b) and I.R.E. 607; admissible as impeachment by contradiction)	Prior incidents were improper character evidence (I.R.E. 404(b)/608(b)) and unfairly prejudicial (I.R.E. 403)	Affirmed: evidence admissible as impeachment by contradiction; court erred in applying 608(b) but alternative bases (I.R.E. 607/403) support admission
3) Motion for new trial based on exclusion of questions about IDOC guidelines	Excluding guideline questions was proper—guidelines marginally relevant and, if relevant, excluded under I.R.E. 403 as confusing/wasteful	Questions about IDOC infraction/disciplinary guidelines were relevant to officers’ motive to lie and excluded in error, warranting new trial	Affirmed: exclusion was not legal error (marginal relevance) and, alternatively, properly excluded under I.R.E. 403

State v. DuValt, 131 Idaho 550 (1998) (issue‑preservation principles; when trial issues may be raised on appeal)
State v. Araiza, 124 Idaho 82 (1992) (confrontation/cross‑examination for bias; trial court may limit harassing or marginal cross‑examination)
United States v. Castillo, 181 F.3d 1129 (9th Cir. 1999) (distinguishes impeachment by contradiction from Rule 608(b) character evidence)
Pierson v. Brooks, 115 Idaho 529 (Ct. App. 1989) (distinguishes impeachment by contradiction from character evidence on veracity)
State v. Ehrlick, 158 Idaho 900 (2015) (all relevant evidence is admissible unless excluded by rule)
State v. Joslin, 145 Idaho 75 (2007) (need for adequate offer of proof to show relevance)