State v. Johnson

CourtIdaho Court of Appeals
DecidedJanuary 8, 2026
Docket50975
StatusUnpublished

This text of State v. Johnson (State v. Johnson) is published on Counsel Stack Legal Research, covering Idaho Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Johnson, (Idaho Ct. App. 2026).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF IDAHO

Docket No. 50975

STATE OF IDAHO, ) ) Filed: January 8, 2026 Plaintiff-Respondent, ) ) Melanie Gagnepain, Clerk v. ) ) THIS IS AN UNPUBLISHED ROBERT DAVID JOHNSON, ) OPINION AND SHALL NOT ) BE CITED AS AUTHORITY Defendant-Appellant. ) )

Appeal from the District Court of the Fourth Judicial District, State of Idaho, Ada County. Hon. Cynthia Yee-Wallace, District Judge.

Order withholding judgment for felony malicious injury to property, affirmed.

Erik R. Lehtinen, State Appellate Public Defender; Brian R. Dickson, Deputy Appellate Public Defender, Boise, for appellant.

Hon. Raúl R. Labrador, Attorney General; Mark W. Olson, Deputy Attorney General, Boise, for respondent. ________________________________________________

LORELLO, Judge Robert David Johnson appeals from an order withholding judgment for felony malicious injury to property. We affirm. I. FACTUAL AND PROCEDURAL BACKGROUND Officers responded to a report that a man was breaking windows at a commercial business. Upon arrival, officers encountered Johnson directly outside the business, standing near the shattered glass. Officers detained Johnson after he ignored commands and continued speaking incoherently. Johnson denied breaking the windows but displayed agitation and hostility toward officers during the encounter.

1 Johnson was charged with felony malicious injury to property. I.C. § 18-7001(2). Before trial, Johnson moved to exclude the officer’s bodycam footage and related testimony showing Johnson’s verbal combativeness toward officers during his arrest, arguing the evidence was irrelevant and unfairly prejudicial. The State contended the evidence was relevant to show Johnson’s identity and malicious intent. The district court deferred ruling. At trial, Johnson objected to testimony about his demeanor during his arrest. The district court overruled the objection, concluding the evidence was relevant to Johnson’s defense theory that he lacked malicious intent toward the property because he only intended self-harm. He also argued the district court’s reliance on the statutory definition of “maliciously” in I.C. § 18-101(4) rendered the admissibility rulings erroneous. After an officer testified that Johnson was belligerent and used a racial slur, Johnson moved for a mistrial. The district court denied the motion, concluding the evidence was relevant to Johnson’s state of mind and intent and that the probative value of the evidence was not substantially outweighed by the danger of prejudice. The district court later admitted the bodycam video on the same grounds. Thereafter, the jury found Johnson guilty. Johnson appeals.1 II. STANDARD OF REVIEW The decision whether to admit evidence at trial is generally within the province of the trial court. A trial court’s determination as to the admission of evidence at trial will only be reversed where there has been an abuse of that discretion. State v. Zimmerman, 121 Idaho 971, 973-74, 829 P.2d 861, 863-64 (1992). When a trial court’s discretionary decision is reviewed on appeal, the appellate court conducts a multi-tiered inquiry to determine whether the lower court: (1) correctly perceived the issue as one of discretion; (2) acted within the boundaries of such discretion; (3) acted consistently with any legal standards applicable to the specific choices before it; and (4) reached its decision by an exercise of reason. State v. Herrera, 164 Idaho 261, 270, 429 P.3d 149, 158 (2018).

1 Johnson also pled guilty to three misdemeanors for resisting or obstructing, possession of a controlled substance and possession of drug paraphernalia, which offenses were included in the order withholding judgment. However, he does not challenge these convictions on appeal.

2 We review questions of relevance de novo. State v. Jones, 167 Idaho 353, 358, 470 P.3d 1162, 1167 (2020); State v. Aguilar, 154 Idaho 201, 203, 296 P.3d 407, 409 (Ct. App. 2012). III. ANALYSIS Johnson argues the district court erred by admitting evidence of his combative demeanor toward the officers, asserting the evidence was irrelevant and its prejudicial effect required exclusion under I.R.E. 403. Johnson also argues the district court erred by denying his motion for a mistrial after an officer testified that Johnson used a racial slur during the arrest. Finally, Johnson contends the cumulative effect of these alleged errors deprived him of a fair trial. The State responds that the evidence was properly admitted as relevant to Johnson’s identity and state of mind, that the isolated reference to the racial slur did not constitute reversible error, and that no errors occurred to cumulate. We hold that Johnson has failed to demonstrate error in the district court’s admission of the evidence or in its denial of his motion for a mistrial. A. Relevance of Johnson’s Demeanor Evidence that is relevant to a material and disputed issue concerning the crime charged is generally admissible. State v. Garcia, 166 Idaho 661, 670-71, 462 P.3d 1125, 1134-35 (2020). Evidence is relevant if it has any tendency to make the existence of any fact that is of consequence to the determination of the action more probable or less probable than it would be without the evidence. I.R.E. 401; Garcia, 166 Idaho at 670, 462 P.3d at 1134. Whether a fact is of consequence or material is determined by its relationship to the legal theories presented by the parties. State v. Johnson, 148 Idaho 664, 671, 227 P.3d 918, 925 (2010). Johnson challenged the admission of evidence depicting his combative demeanor toward officers, arguing the conduct was irrelevant to the malicious injury to property charge. The district court admitted the evidence as relevant both to identity and state of mind considering the defense presented. The record supports admission on both grounds. Officers encountered Johnson within minutes of the report, directly outside the damaged storefront. The disputed portion of the bodycam video depicted Johnson’s appearance, proximity, and conduct at the scene. Evidence that places a defendant at the scene and corroborates eyewitness testimony satisfies the low threshold of relevance. See State v. Ogden, 171 Idaho 258, 273, 519 P.3d 1198, 1213 (2022)

3 (holding that evidence of defendant’s location and conduct at the scene is relevant to identity). Because Johnson’s identity was disputed, the evidence bore on a fact of consequence. In addition, Johnson argued he lacked the requisite malicious intent because he was distressed or attempting to harm himself. Johnson’s behavior during the arrest constituted circumstantial evidence bearing on his intent. The district court admitted the evidence for that limited purpose, not for proving his propensity. Where a defendant places mental state directly at issue, contemporaneous conduct may carry probative value. State v. Fox, 170 Idaho 846, 862, 517 P.3d 107, 123 (2022). By advancing this defense, Johnson placed his mental state directly at issue. Johnson’s argument that the district court applied the wrong definition of “maliciously” does not alter this conclusion. Although State v.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Adamcik
272 P.3d 417 (Idaho Supreme Court, 2012)
State v. Johnson
227 P.3d 918 (Idaho Supreme Court, 2010)
State v. Javier Aguilar
296 P.3d 407 (Idaho Court of Appeals, 2012)
State v. Vance Everett Thumm
285 P.3d 348 (Idaho Court of Appeals, 2012)
State v. Urquhart
665 P.2d 1102 (Idaho Court of Appeals, 1983)
State v. Clark
772 P.2d 263 (Idaho Court of Appeals, 1989)
State v. Zimmerman
829 P.2d 861 (Idaho Supreme Court, 1992)
State v. Enno
807 P.2d 610 (Idaho Supreme Court, 1991)
State v. James Leroy Skunkcap
335 P.3d 561 (Idaho Supreme Court, 2014)
State v. Herrera
429 P.3d 149 (Idaho Supreme Court, 2018)
State v. Jones
470 P.3d 1162 (Idaho Supreme Court, 2020)
State v. Fox
517 P.3d 107 (Idaho Supreme Court, 2022)
State v. Ogden
519 P.3d 1198 (Idaho Supreme Court, 2022)
State v. Garcia
462 P.3d 1125 (Idaho Supreme Court, 2020)

Cite This Page — Counsel Stack

Bluebook (online)
State v. Johnson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-johnson-idahoctapp-2026.