State v. Joseph Anthony Thomas, Jr., 342 P.3d 628

Thomas was convicted of first-degree murder for the strangulation of Beth Irby Thomas.
Prosecutor moved to exclude evidence that Decedent engaged in erotic asphyxiation; defense sought to introduce corroborating statements.
District court granted in limine exclusion, then allowed narrowly some autoerotic asphyxia evidence if connected to prior acts.
During trial, Thomas testified about Decedent's past sexual behavior and belt use; psychologist testified on autoerotic asphyxia.
Jury asked whether others testified to Decedent’s interest in autoerotic asphyxiation; court instructed to rely on memory alone; verdict returned.
Idaho Court of Appeals affirmed exclusion as harmless error; Supreme Court vacated verdict and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether exclusion of evidence about Decedent’s erotic asphyxiation violated the defendant’s right to present a defense	State contends evidence irrelevant; exclusion proper under Rule 403	Thomas argues evidence relevant to defense and corroborates his version	Reversed; exclusion violated due process; error not harmless beyond a reasonable doubt

State v. Meister, 148 Idaho 236, 220 P.3d 1055 (2009) (defendant's right to present a defense; relevance standard)
State v. Russo, 157 Idaho 299, 336 P.3d 232 (2014) (relevance and evidentiary standards; de novo review of relevance)
State v. Perry, 150 Idaho 209, 245 P.3d 961 (2010) (harmless-error standard for constitutional errors)
Sullivan v. Louisiana, 508 U.S. 275 (1993) (constitutional harmless-error standard (beyond reasonable doubt))
State v. Skunkcap, 157 Idaho 221, 335 P.3d 561 (2014) (harmless-error considerations in constitutional error)
State v. Suriner, 154 Idaho 81, 294 P.3d 1093 (2013) (direct review standard for appeals from Court of Appeals)
State v. Oliver, 144 Idaho 722, 170 P.3d 387 (2007) (credibility and weight afforded to witness testimony)