State v. Michael Eugene Koch, 157 Idaho 89

Koch was convicted by jury of four counts of lewd conduct with a minor under sixteen for acts involving a 13-year-old, C.C., in 2011.
Indictment alleged counts based on different sexual-contact theories occurring January–May 2011 and April 2011.
C.C. testified Koch engaged in sexual acts with her at Koch’s home while his wife and daughter were away; an audio confrontation call was admitted.
Koch argued multiple evidentiary errors, including expert disclosures, foundation and relevance rulings, and admission of impeachment and other testimony.
The district court imposed concurrent 25-year sentences with five years fixed on each count; Koch appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
SR 16(b)(7) disclosures sufficient?	Koch argues Yeager disclosures were insufficient.	Koch contends State failed to disclose facts/data behind Yeager’s opinions.	Disclosures were sufficient; record supports court's ruling.
Opening statement comments proper?	Koch argues prosecutor’s grooming summary was improper and prejudicial.	State contends statements were fair summaries of evidence.	Court did not abuse discretion; opening statement allowed.
Foundation and admission of text/email/recordings?	Koch challenges foundation for texts, emails, and the confrontation call.	State provided proper foundation; objections weight or admissibility.	Most foundations upheld; some errors; harmless overall on balance.
Relevance of specific testimony?	Koch claims certain grooming-related testimony was irrelevant.	State contends grooming testimony was probative of charged conduct.	Court held challenged testimony relevant to grooming, not reversible error.
Impeachment of Salina Koch’s prior statement admissible?	Koch argues improper impeachment via Salina’s prior statements about marriage and innocence.	State relies on Rule 613 and inconsistent statements.	Impeachment evidence properly admitted; not cumulatively prejudicial.

State v. Stradley, 127 Idaho 203 (1995) (upholds discovery violation review with substantial evidence)
United States v. Lipscomb, 539 F.3d 32 (1st Cir. 2008) (notice for expert bases sufficiency; breadth varies by subject)
State v. Glass, 146 Idaho 77 (Ct. App. 2008) (admissibility of online transcripts; foundation tying to conduct)
In re F.P., 878 A.2d 91 (Pa. Super. Ct. 2005) (electronic communications authenticated by circumstantial factors)
State v. Perry, 150 Idaho 209 (2010) (impeachment evidence; relevance and preservation requirements)
State v. Truman, 150 Idaho 714 (Ct. App. 2011) (grooming evidence relevance in sexual abuse cases)