State v. Javier Aguilar, 296 P.3d 407

Aguilar was convicted by a jury of three counts of lewd conduct with a minor under sixteen.
The district court imposed a unified life term with a seven-year minimum for each count, to be served consecutively (aggregate life with 21-year minimum).
On appeal, Aguilar challenged the admission of a counselor’s trial testimony regarding long-term impacts of sexual abuse on victims as irrelevant.
The counselor testified in general terms about long-term effects (chemical dependency, body image, anger, self-esteem, anxiety, etc.).
The court ultimately affirmed the judgment and held the challenged testimony harmless error and the sentence reasonable.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the counselor testimony admissible as relevant evidence?	Aguilar argued testimony was irrelevant under 401/402.	Aguilar argued it should have been excluded as irrelevant.	Testimony was irrelevant; reversed on that point but harmless.
Was the error in admitting testimony harmless beyond a reasonable doubt?	State contends harmless if overwhelming proof exists.	Aguilar contends any error could affect verdict.	Harmless error; overwhelming evidence against Aguilar.
Did the district court abuse its discretion in sentencing?	Aguilar claims aggregate life sentence excessive.	Aguilar asserts district court relied on improper factors.	No abuse of discretion; aggregate life with 21-year minimum affirmed.

State v. Raudebaugh, 124 Idaho 758 (1993) (relevance de novo review for evidentiary questions)
State v. Dutt, 139 Idaho 99 (Ct. App. 2003) (testimony about victim credibility can be expert)
State v. Blackstead, 126 Idaho 14 (Ct. App. 1994) (expert testimony aiding credibility assessment)
State v. Field, 144 Idaho 559 (2007) (harmless-error standard for evidentiary rulings)
State v. Hall, 727 P.2d 1255 (Ct. App. 1986) (harmless error review framework)
State v. Toohill, 103 Idaho 565 (Ct. App. 1982) (standard for evaluating sentence excessiveness)
State v. Reinke, 653 P.2d 1184 (Ct. App. 1982) (independent review of sentencing discretion)
State v. Oliver, 170 P.3d 387 (Ct. App. 2007) (consider entire sentence in abuse-of-discretion review)