State v. Marvin Orellana-Castro, 351 P.3d 1215

defendant Marvin Orellana-Castro was charged with unlawful sexual contact and multiple counts of sexual abuse involving his two minor stepdaughters (ages 11–12 and 13–14)
district court denied severance, finding a common scheme or plan supported by proximity in time and location
trial occurred in July 2012 to a jury; expert testimony addressed older girl's PTSD and other therapists linked symptoms to abuse
State sought to admit evidence of rape of the older girl at a quinceañera; district court excluded under Idaho Rule of Evidence 412
jury convicted on four counts (two for the older girl, two for the younger girl); counts for lewd conduct regarding the older girl remained unresolved
Idaho Supreme Court vacated the judgment and remanded for further proceedings, holding error in denial of severance and lack of harmless-error analysis

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did district court err in denying severance of charges?	Orellana-Castro argues joinder improperly aggregated separate offenses.	State contends joinder proper under Rule 8 due to common scheme.	Yes; abuse of discretion; severance required.
Was joinder proper under Rule 8 and did the court properly assess common scheme?	State asserts shared home and timing show common plan; Johnson/Johnson analysis supports.	Defendant argues lack of common scheme; prejudicial impact of joinder.	No; court failed to perform Grist/Johnson analysis; prejudicial error.
Was evidence of the older girl's prior rape admissible under Rule 412?	State sought to admit to explain PTSD source under 412(b)(2)(A).	Defense argued it showed source of emotional trauma; not physical injury.	No; district court did not err in excluding as to physical injury; admissibility under other subsections not decided.

State v. Field, 144 Idaho 559 (2007) (joinder and severance review; abuse of discretion standard)
State v. Grist, 147 Idaho 49 (2009) (common scheme or plan analysis; limits on admissibility of other acts to prove scheme)
State v. Johnson, 148 Idaho 664 (2010) (shared characteristics insufficient for common scheme; need more than family relation and juvenile status)
State v. Pepcorn, 152 Idaho 678 (2012) (abuse of discretion; standard for 404(b) admissibility in severed cases)
State v. Dambrell, 120 Idaho 532 (1991) (abuse of discretion standard for denial of severance)
State v. Suriner, 154 Idaho 81 (2013) (direct review of Court of Appeals decision; standard of review for trial court rulings)