State v. Rodriguez, 48151

Defendant Rene Rodriguez was charged with one count of child sexual abuse of a minor, four counts of lewd conduct with a child under sixteen, and one count of rape based on allegations by his adopted daughter S.R. covering ages nine to seventeen.
S.R. first told her mother about abuse around 2005–2006, but did not report again until 2018 after hearing her brother say S.R.’s younger sister was sleeping in Rodriguez’s bed.
The State sought to admit evidence explaining S.R.’s 2018 delayed disclosure (the brother’s statement about the younger sister sleeping in Rodriguez’s bed); the district court admitted that testimony for the non‑hearsay effect on S.R. and under a 404(b) two‑tier analysis, with limiting instructions.
Rodriguez attempted to introduce testimony that S.R. was hospitalized for a week (and did not disclose then); the district court excluded that testimony as cumulative with other undisputed non‑disclosures and because it risked opening the door to previously excluded 404(b) evidence.
At trial the State’s expert testified about delayed disclosure, grooming, and family dynamics; a jury convicted Rodriguez on all counts and he appealed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Rodriguez)	Held
Admissibility of testimony that S.R. learned her sister slept in Rodriguez’s bed (used to explain delayed disclosure)	Evidence is relevant to explain why S.R. delayed disclosure and affects credibility; probative value outweighs prejudice; admissible for non‑hearsay effect and permissible 404(b) purpose	Evidence functions as improper propensity/bad‑acts evidence and is unduly prejudicial and confusing; I.R.E. 403 exclusion required	Court affirmed admission: trial court did not abuse discretion; probative value of explaining delayed disclosure outweighed prejudice; limiting instruction appropriate
Exclusion of testimony that S.R. was hospitalized for a week and did not disclose during that time	N/A (defense sought admission)	Hospitalization was highly probative of nondisclosure and undermined victim credibility and the State expert’s explanation of delayed disclosure; neutral chance to disclose	Court affirmed exclusion: trial court acted within discretion — evidence was cumulative, had minimal additional probative value, and risked opening door to previously excluded 404(b) evidence
Cumulative‑error claim (trial errors in aggregate deprived defendant of fair trial)	N/A	Even if individual rulings were erroneous, cumulative errors together warrant reversal	Court rejected cumulative‑error claim: appellant failed to show multiple errors; no relief warranted

State v. Grist, 147 Idaho 49, 205 P.3d 1185 (2009) (I.R.E. 404(b) prohibits propensity use but allows evidence for other purposes; two‑step admissibility analysis)
State v. Pepcorn, 152 Idaho 678, 273 P.3d 1271 (2012) (404(b) evidence may be admissible for non‑propensity purposes listed in the rule)
State v. Diggs, 141 Idaho 303, 108 P.3d 1003 (Ct. App. 2005) (delayed‑disclosure evidence explaining timing of report can be admissible and probative despite potential prejudice)
State v. Norton, 151 Idaho 176, 254 P.3d 77 (Ct. App. 2011) (appellate deference to trial court’s balancing on admissibility absent abuse of discretion)
State v. Herrera, 164 Idaho 261, 429 P.3d 149 (2018) (standards for reviewing discretionary trial court rulings)
State v. Hall, 163 Idaho 744, 419 P.3d 1042 (2018) (presumption that juries follow limiting instructions)
State v. Smith, 117 Idaho 225, 786 P.2d 1127 (1990) (trial court’s broad discretion in admitting or excluding testimonial evidence)
State v. Knight, 128 Idaho 862, 920 P.2d 78 (Ct. App. 1996) (trial court may exclude relevant evidence as cumulative under I.R.E. 403)