State v. Ricardo Ozuna, Jr., 155 Idaho 697

Defendant Ricardo Ozuna Jr. was convicted of lewd conduct with a minor under 16 and of having a prior sexual-offense conviction; sentenced to unified life with 20-year minimum, sentence enhanced for prior conviction.
Alleged victim was 15; rape kit showed chlamydia at the time of the incident.
Ozuna proffered evidence that (1) he learned from a third party the victim had an STD before the contact and (2) he never contracted the STD, arguing this supported his claim he avoided intercourse to avoid infection.
The district court excluded the STD-related evidence under Idaho Rule of Evidence 412 (rape-shield), treating it as reputation/opinion or past sexual behavior and finding probative value outweighed by unfair prejudice.
Ozuna argued exclusion violated his Sixth and Fourteenth Amendment right to present a defense; he also challenged the severity of his sentence based on mitigation (family support, substance-abuse history).
The Court of Appeals affirmed: evidence exclusion was within the court’s discretion and constitutionally permissible; the life-with-20-years sentence was not an abuse of discretion given Ozuna’s prior similar felony and repeated parole revocations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of victim's STD evidence under I.R.E. 412	State: STD evidence is barred as past sexual behavior and prejudicial under I.R.E. 412	Ozuna: Evidence shows his state of mind (fear of disease) and corroborates denial of intercourse; not "past sexual behavior"	Court: Evidence falls within I.R.E. 412 as past sexual behavior; exclusion was not an abuse of discretion
Constitutional right to present a defense and exclusion of evidence that Ozuna did not contract STD	State: legitimate interests (victim privacy, prejudice) outweigh weak probative value; no door opened for rebuttal	Ozuna: Exclusion violated Sixth/Fourteenth Amendments because evidence was relevant to his defense and credibility	Court: Defendant has no right to present irrelevant or marginally relevant evidence; trial court balanced interests and did not err—no constitutional violation
Excessiveness of sentence	State: sentence justified by public protection, defendant's history, and offense seriousness	Ozuna: mitigating factors (family support, substance abuse) warrant leniency	Court: Independent review finds sentence not plainly excessive given prior similar felony, parole revocations, lack of remorse, and danger to minors

State v. Perry, 139 Idaho 520 (discretion in evidentiary rulings)
State v. Hedger, 115 Idaho 598 (standard for reviewing discretionary rulings)
State v. Self, 139 Idaho 718 (limits of Sixth Amendment right to present evidence under I.R.E. 412)
State v. Peite, 122 Idaho 809 (when rape-shield exclusion may implicate constitutional rights)
Michigan v. Lucas, 500 U.S. 145 (legitimate state interests in protecting rape victims from invasive questioning)
Commonwealth v. Thevenin, 603 N.E.2d 222 (circumstances where exclusion of STD state-of-mind evidence may violate right to present a defense)