State v. Joseph Anthony Thomas, Jr.

Summary

The Idaho Supreme Court held that the district court violated the defendant’s constitutional right to present a defense by excluding evidence that the victim had previously engaged in or expressed an interest in erotic asphyxiation. Because the State did not establish beyond a reasonable doubt that the error was harmless, the court vacated the murder conviction and judgment and remanded for further proceedings.

Holdings

1. The district court committed constitutional error by excluding evidence that could have corroborated Thomas's account and was relevant to whether he intentionally killed the victim.
2. The State failed to establish beyond a reasonable doubt that the constitutional error did not affect the jury's verdict.

Questions Presented

1. Whether the district court erred by excluding testimony from the victim's friends and boyfriend concerning her prior interest in erotic asphyxiation.
2. Whether the constitutional error in excluding that evidence was harmless beyond a reasonable doubt.

Disposition

vacated