State v. Ryan Dean Bevard

Bevard attempted to buy a speaker with counterfeit bills, left the store when a clerk went for a manager, and was later arrested after fleeing police and falsely reporting a shooting.
State charged Bevard with forgery (felony) plus misdemeanors; because of prior grand theft and burglary felonies the State sought a persistent violator enhancement.
The State gave notice under I.R.E. 609 it would impeach Bevard with the fact and nature of his prior felony convictions if he testified.
The district court held a hearing, found the prior convictions were relevant (Tier II felonies), and admitted both the fact and nature of the prior convictions, concluding probative value outweighed prejudice.
Bevard testified, denied knowledge the bills were counterfeit, and admitted the prior convictions; jury convicted him of forgery and the persistent violator enhancement.
On appeal Bevard argued the court abused its discretion under I.R.E. 609 by allowing the State to elicit the nature (not just the fact) of his prior convictions because they were too similar to the charged offense.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion under I.R.E. 609 by allowing impeachment with the nature of prior felony convictions	State: nature of prior grand theft and burglary is relevant to credibility; probative value outweighs prejudice given centrality of credibility and Tier II status	Bevard: prior convictions are sufficiently similar to forgery that the nature is unduly prejudicial and should be limited to proof of the fact of convictions only	Court affirmed: no abuse of discretion; nature admissible because convictions were Tier II, credibility was central, and similarity did not make prejudice outweigh probative value

State v. Thompson, 132 Idaho 628, 977 P.2d 890 (Idaho 1999) (sets two‑prong I.R.E. 609 test and lists factors balancing probative value vs. prejudice)
State v. Rodgers, 119 Idaho 1066, 812 P.2d 1227 (Ct. App. 1991) (admission of nature of prior conviction improper where prior crime closely resembled charged crime)
State v. Ybarra, 102 Idaho 573, 634 P.2d 435 (Idaho 1981) (categorization of felonies for impeachment relevance; burglary as crime involving dishonesty)
State v. Hedger, 115 Idaho 598, 768 P.2d 1331 (Idaho 1989) (standard of review for discretionary rulings)
State v. Grist, 152 Idaho 786, 275 P.3d 12 (Ct. App. 2012) (explains three felony categories and their relation to credibility)