State v. Jeffery Alan Baker
161 Idaho 289
| Idaho Ct. App. | 2016Background
- Defendant Jeffery Alan Baker was convicted of first-degree murder for the death of his 11‑week‑old daughter, G.B.; sentence: unified life with 15 years determinate.
- Prosecution theory: G.B. died from abusive head trauma/aggravated battery (violent shaking or blunt force trauma) that caused loss of consciousness and secondary airway obstruction leading to global ischemic encephalopathy.
- Medical evidence: State experts (including a neuropathologist and a pediatrician) testified death resulted from abusive head trauma/shaking; defense experts testified death resulted from natural causes (cerebral venous thrombosis).
- Trial evidence included an animated video (Exhibit 3) depicting injuries from shaking, admitted for illustrative purposes; a still image from that animation was used repeatedly in the State’s closing.
- Procedural notes: First trial ended in mistrial; this was the second trial. Baker did not request a specific unanimity instruction at trial and objected at trial to the video and the State’s use of the still image during closing.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Baker) | Held |
|---|---|---|---|
| Whether a specific unanimity instruction was required on the method causing death | No; only one crime (aggravated battery → murder) was charged; alternative causal pathways (shaking, blunt force, secondary airway obstruction) were part of a single continuous course of conduct, so no specific unanimity instruction was necessary | Jury should have been instructed to unanimously agree on which distinct crime/mens rea produced death because evidence suggested either aggravated battery or negligent placement producing airway obstruction (involuntary manslaughter) | Affirmed: No specific unanimity instruction required; acts formed one continuous offense and alternative means need not be unanimously agreed upon |
| Whether the animated video (Exhibit 3, clip 2) was admissible | Video was relevant and admissible as an illustrative exhibit to assist expert testimony about mechanism of injury; degree differences did not render it inadmissible | Video was irrelevant or misleading because it depicted injuries more severe or different than those in this case and was unduly prejudicial | Affirmed: District court did not abuse discretion; video was relevant and probative and not unfairly prejudicial when admitted with limiting instruction |
| Whether prosecution committed misconduct by repeatedly using a still image from the animation in closing | Use was proper: illustration had been admitted and limiting instructions were given; counsel has latitude in closing | Repeated use improperly appealed to emotion and exceeded illustrative scope, warranting reversal | Affirmed: Not prosecutorial misconduct; use was within permissible closing argument and limited by jury instruction |
| Whether cumulative errors deprived Baker of due process / fair trial | No prejudicial errors demonstrated; cumulative‑error doctrine inapplicable without multiple errors | Combined trial errors (unanimity omission, video admission, closing image) denied due process | Affirmed: No individual errors established, so no cumulative error or Fourteenth Amendment violation |
Key Cases Cited
- State v. Severson, 147 Idaho 694 (Idaho 2009) (no unanimity instruction required where murder charged as single act though alternative means alleged)
- State v. Miller, 135 Idaho 261 (Ct. App. 2000) (unanimity required where multiple separate, distinct offenses alleged)
- State v. Stevens, 146 Idaho 139 (Idaho 2008) (illustrative video admissible to support expert testimony even if not exact depiction)
- Schad v. Arizona, 501 U.S. 624 (U.S. 1991) (jury need not agree on the same factual theory; alternative means doctrine)
- State v. Adamcik, 152 Idaho 445 (Idaho 2012) (cumulative‑error doctrine requires multiple errors)
- State v. Bush, 131 Idaho 22 (Idaho 1997) (test for whether conduct is single continuous offense or multiple distinct crimes)