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State v. Diaz

507 P.3d 1109, 170 Idaho 79 (2022)

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State v. Diaz

Idaho Supreme Court
507 P.3d 1109, 170 Idaho 79 (2022)

Facts

When Ruben Diaz (defendant) approached stranger Clyde Vinsonhaler in Vinsonhaler’s front yard, Vinsonhaler thought Diaz appeared disoriented and lost. After speaking briefly with Diaz, Vinsonhaler decided to go inside and call the police for help. Diaz followed Vinsonhaler inside and stabbed Vinsonhaler multiple times in the face and elsewhere before police arrived. Vinsonhaler was severely injured. The state charged Diaz with aggravated battery. Diaz informed the state that he intended to offer testimony from Dr. James Davidson in his defense. Davidson would testify that Diaz was delusional at the time of the stabbing and believed he was attacking an alien, rather than a human, thus negating the mens rea, or criminal intent, necessary for aggravated battery. The state filed a motion in limine, or a pretrial motion seeking a ruling on the admissibility of evidence, asking the court to exclude Davidson’s testimony. The state argued that the testimony was irrelevant and advanced an insanity defense that was no longer recognized under Idaho law. The district court denied the motion, holding that Davidson’s testimony was relevant to negate the necessary intent for aggravated battery or to prove a mistake-of-fact defense. The state appealed to the Idaho Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Bevan, C.J.)

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