State v. Ruiz
150 Idaho 469
Idaho2010Background
- A confidential informant participated in a meth sale observed by law enforcement; Morrison was identified as the seller by the informant.
- Morrison and Ruiz were charged with trafficking, Morrison pled to a reduced charge and agreed to testify for the State against Ruiz, with no minimum sentence for Morrison.
- During Ruiz's trial, Morrison testified and misrepresented probation discussions; Ruiz's counsel sought a recess to address the issue.
- Prosecutor instructed that there should be no mention of Morrison's avoided minimum sentence; the district court prohibited questioning about the minimum sentence.
- Ruiz was convicted; on appeal, the Court of Appeals upheld Confrontation Clause claims but did not address Rule 403; this Court granted review.
- Idaho Supreme Court vacated Ruiz's conviction for failure to conduct Rule 403 balancing and remanded for proceedings consistent with the opinion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Rule 403 violated by excluding minimum-sentence evidence? | Ruiz | Ruiz | Yes; district court failed to perform Rule 403 balancing |
| Did the district court's ruling infringe the Confrontation Clause? | Ruiz | Ruiz | Not reached; vacated before ruling due to Rule 403 error |
Key Cases Cited
- Meister, 148 Idaho 236 (2009) (evidence relevance and Rule 403 balancing framework)
- DeRushé v. State, 200 P.3d 1148 (2009) (direct review on petition for discretionary review by Supreme Court)