State v. Robert Conrad MacNeilage
Background
- MacNeilage, who repaired and resold cars, bought a BMW to fix and sell, then reported it damaged while towing; insurer paid a total-loss claim for the BMW and a truck.
- Former business partner Ronald later told the insurer MacNeilage admitted intentionally damaging the vehicles; a former employee Tanner said he was with MacNeilage when the BMW was intentionally damaged.
- State charged MacNeilage with four counts of insurance fraud; a jury convicted him on two counts and the other two were dismissed without prejudice.
- At trial defense sought to impeach two State witnesses (Justin and Richard) with the nature of their felony convictions; the court allowed inquiry into the fact of felony convictions but excluded the specific nature of the crimes.
- Court sentenced MacNeilage to concurrent unified six-year sentences with two years determinate, retained jurisdiction initially, then later relinquished jurisdiction after correctional-facility recommendation; MacNeilage appealed conviction, sentence, and relinquishment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of specific nature of prior felony convictions for impeachment (I.R.E. 609) | Trial court properly limited impeachment to fact of felony to avoid undue prejudice | MacNeilage: should have been allowed to elicit nature of convictions (credit‑card theft, burglary) because relevant to credibility | Court: Trial court misstated and failed to fully make required 609 findings, but any error was harmless beyond a reasonable doubt — admission of only the fact of conviction did not contribute to verdict |
| Excessive sentence | State: sentence reasonable to protect public and deter based on criminal history | MacNeilage: six years concurrent (two determinate) excessive given mitigating factors (family support, work history) | Court: independent review finds no abuse of discretion; sentence reasonable to protect society and deter |
| Relinquishment of retained jurisdiction | State: court properly followed correctional facility recommendation based on poor program compliance and risk | MacNeilage: court ignored rehabilitative accomplishments and attributed some misconduct to inmate dynamics | Court: no abuse of discretion in relinquishing jurisdiction given record of noncompliance and risk of reoffending |
Key Cases Cited
- State v. Bush, 131 Idaho 22 (Idaho 1997) (two‑part Rule 609 analysis: relevance to credibility and probative vs. prejudicial balancing)
- State v. Grist, 152 Idaho 786 (Ct. App. 2012) (limited impeachment value where prior offense lacks element of deceit)
- State v. Franco, 128 Idaho 815 (Ct. App. 1996) (court must make record explaining Rule 609 determinations and weigh probative value against prejudice)
- Chapman v. California, 386 U.S. 18 (U.S. 1967) (harmless‑beyond‑a‑reasonable‑doubt standard for constitutional error)
- State v. Perry, 150 Idaho 209 (Idaho 2010) (appellate harmless‑error principles applied to constitutional and nonconstitutional error)