State v. Rodriguez, 48067

Rodriguez drove a vehicle that "t-boned" a pizza delivery driver and thereafter struck a fire hydrant; two independent witnesses observed him swerve around their car and enter the intersection alone.
After the collision Rodriguez exited his vehicle and fled on foot; the two witnesses pursued him, parked nearby, and later guided police to where he was sitting in a plaza.
At arrest an officer observed glassy, bloodshot eyes and slurred speech; a warrant blood draw later showed a BAC of .219.
Rodriguez was charged with felony DUI, leaving the scene of an accident, failure to notify upon striking a fixture, possession of an open container, and a persistent-violator enhancement.
At trial Rodriguez testified; the district court allowed impeachment with the fact (but not the nature) of his most recent felony conviction (2017 DUI). On cross-exam the prosecutor asked whether he had a prior felony, and Rodriguez admitted he did.
The jury convicted on the four substantive counts and Rodriguez admitted the persistent-violator allegation; on appeal he argued admission of the fact of his prior felony for impeachment under I.R.E. 609 was erroneous. The Court of Appeals affirmed, holding any error harmless beyond a reasonable doubt.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether admission of the fact of Rodriguez's prior felony conviction for impeachment under I.R.E. 609 was erroneous and, if so, whether any error was harmless	State: Any error was harmless because the total evidence of guilt and credibility issues made the single reference immaterial	Rodriguez: The court applied the wrong legal standard and permitting the jury to learn he was a felon unfairly prejudiced credibility and invited propensity inference	The court assumed any error in admitting the fact of the prior felony and analyzed harmlessness; the error was harmless beyond a reasonable doubt, and convictions were affirmed

State v. Montgomery, 163 Idaho 40 (2017) (appellate burden to show nonconstitutional error was harmless beyond a reasonable doubt)
Yates v. Evatt, 500 U.S. 391 (1991) (definition of harmless error in relation to the entire record)
State v. Garcia, 166 Idaho 661 (2020) (apply harmless-error analysis comparing probative force of record absent the error to the effect of the error)
Kotteakos v. United States, 328 U.S. 750 (1946) (need to consider effect the error had or might have had on the jury in the context of the whole trial)