State of Idaho v. Jessica Anne Vazquez

── State of Idaho v. Jessica Anne Vazquez ── Court: Idaho Supreme Court Date: May 29, 2026 Category: General IN THE SUPREME COURT OF THE STATE OF IDAHO Docket No. 53369 STATE OF IDAHO, ) ) Plaintiff-Respondent, ) Boise, April 2026 Term ) v. ) Opinion Filed: May 29, 2026 ) ) Melanie Gagnepain, Clerk JESSICA ANNE VAZQUEZ, ) ) Defendant-Appellant, ) ____________________________________) Appeal from the District Court of the Fifth Judicial District of the State of Idaho, Blaine County. Ned Williamson, District Judge. The judgment of the district court is affirmed. Erik R. Lehtinen, State Appellate Public Defender, Boise, for Appellant. Jacob Westerfield argued. Raúl R. Labrador, Idaho Attorney General, Boise, for Respondent. Kacey Jones argued. _________________________________ BEVAN, Chief Justice. This appeal concerns what evidence the State may use to rebut an entrapment defense. Specifically, whether the State can introduce evidence of a defendant’s conduct after the events giving rise to the charges to show that a defendant was ready and willing to engage in criminal conduct prior to being contacted by the government. Jessica Anne Vazquez appeals from her conviction for trafficking in methamphetamine and delivery of heroin. Vazquez’s charges arise from a drug sale to a confidential informant (“CI”) on December 1, 2020. At trial, Vazquez did not dispute that she sold heroin or trafficked methamphetamine and instead raised an entrapment defense. The State presented a variety of evidence to rebut Vazquez’s defense, including an exhibit containing text messages between her and the CI dating from December 2020 until June 2021. The district court admitted those text messages over Vazquez’s objection on relevancy and foundational grounds. The jury ultimately 1 convicted her of both charges. The district court subsequently sentenced Vazquez to eight years imprisonment with three years fixed for the trafficking charge consecutive to a one-year fixed sentence for the delivery charge. On appeal, Vazquez asserts that the district court erred in admitting the text messages because they were not relevant to her entrapment defense and their probative value was substantially outweighed by their prejudicial effect. She argues that the text messages only show her state of mind after her first conversation with the CI and have no bearing on whether she lacked the disposition to sell controlled substances prior to that contact. Finally, Vazquez argues that the district court abused its discretion in sentencing her. The Idaho Court of Appeals affirmed the district court, holding that the text messages were relevant to rebut Vazquez’s entrapment defense and that the district court did not abuse its discretion in admitting them. Further, the Court of Appeals upheld Vazquez’s sentence. This Court subsequently granted Vazquez’s petition for review. I. FACTUAL AND PROCEDURAL BACKGROUND On December 1, 2020, Vazquez sold approximately 84 grams of methamphetamine and a gram of heroin to a CI working for the Blaine County Sheriff’s Office (the “controlled buy”).1 Following the controlled buy, on June 25, 2021, a grand jury returned an indictment charging Vazquez with two felony counts for violating Idaho Code section 37-2732B(a)(4)(A), trafficking in methamphetamine, and Idaho Code section 37-2732(a)(1)(A), delivery of heroin. The matter proceeded to a three-day jury trial beginning November 1, 2021. At trial, Vazquez did not contest that she sold drugs to the CI at the controlled buy and instead raised an en