State v. Wilson, 47358

Wilson shot Pat Brown in the back of the head in her basement; Brown was transported to a clinic and died from the wound.
Wilson called police, was found at the scene, and gave recorded interviews admitting he shot Brown and that he had obtained a gun despite being a convicted felon and thus ineligible to possess firearms.
Charged with first-degree murder and a weapons enhancement; defense moved to exclude evidence of Wilson’s prior felony and asked recordings be redacted.
District court allowed unredacted interview recordings (which mentioned Wilson’s felony status) as relevant to premeditation/state of mind, excluding detailed facts of the prior felony absent opening the door.
Jury convicted Wilson of first-degree murder; court sentenced him to life with 30 years determinate plus a five-year weapons enhancement, and later denied his I.C.R. 35 motion for reduction.
Wilson appealed, arguing erroneous admission of prior-conviction evidence, an excessive sentence, and abuse of discretion in denying his Rule 35 motion; the Court of Appeals affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Wilson)	Held
Admission of prior felony evidence (I.R.E. 404(b)/609)	Evidence that Wilson was a felon and knew he couldn’t possess firearms was probative of premeditation, malice, and state of mind; probative value outweighed prejudice	Admission of prior felony was unfairly prejudicial and not admissible under I.R.E. 404(b) or 609; probative value minimal	Affirmed: district court did not abuse discretion; relevance to premeditation justified unredacted tape; 609 not implicated on appeal
Sentence excessive	Sentence necessary to protect public, deter, and reflect defendant’s history (violent prior, alcohol dependency, intermittent explosive disorder)	Sentence overly harsh; court failed to sufficiently consider rehabilitation and mitigating evidence (acceptance of responsibility)	Affirmed: sentence within statutory limits and reasonable given offense, offender history, and need to protect public
Denial of I.C.R. 35 motion	Court properly exercised discretion; exhibits did not present new, convincing information warranting reduction	Court misunderstood scope of discretion and should have reduced determinate term based on new exhibits showing mitigation	Affirmed: court considered exhibits, found them unpersuasive to justify reduction, and did not abuse discretion

State v. Herrera, 164 Idaho 261, 429 P.3d 149 (Idaho 2018) (abuse-of-discretion review framework for evidentiary rulings)
State v. Grist, 147 Idaho 49, 205 P.3d 1185 (Idaho 2009) (Rule 404(b) admissibility principles)
State v. Parmer, 147 Idaho 210, 207 P.3d 186 (Idaho Ct. App. 2009) (404(b) analysis steps: occurrence, relevance, 403 balancing)
State v. Norton, 151 Idaho 176, 254 P.3d 77 (Idaho Ct. App. 2011) (judicial deference to trial court’s 403 balancing)
State v. Toohill, 103 Idaho 565, 650 P.2d 707 (Idaho Ct. App. 1982) (confinement reasonable if necessary to protect society and accomplish sentencing goals)
State v. Oliver, 144 Idaho 722, 170 P.3d 387 (Idaho 2007) (consider entire sentence on review)
State v. Knighton, 143 Idaho 318, 144 P.3d 23 (Idaho 2006) (I.C.R. 35 is plea for leniency reviewed for abuse of discretion)
State v. Huffman, 144 Idaho 201, 159 P.3d 838 (Idaho 2007) (Rule 35 requires new or additional information to justify reduction)