State Response to Motion in Limine 4

Electronically Filed
3/17/2025 5:25 PM

Fourth Judicial District, Ada County Trent Tripple, Clerk of the Court
By: Jennifer Keyes, Deputy Clerk
LATAH COUNTY PROSECUTOR'S OFFICE

WILLIAM W. THOMPSON, JR., ISB No. 2613
PROSECUTING ATTORNEY

JEFF NYE, ISB 9238

SPECIAL ASSISTANT ATTORNEY GENERAL

Latah County Courthouse 522 S. Adams Street, Ste. 211 Moscow, ID 83843
Phone: (208) 883-2246 paservice@latahcountyid.gov
IN THE DISTRICT COURT OF THE FOURTH JUDICIAL DISTRICT OF THE
STATE OF IDAHO, IN AND FOR THE COUNTY OF ADA

STATE OF IDAHO, Case No. CR01-24-31665 Plaintiff,
STATE'S RESPONSE TO

V. DEFENDANT'S MOTION IN

LIMINE # 4

BRYAN C. KOHBERGER, RE: USE OF TERMS

Defendant. PSYCHOPATH OR SOCIOPATH COMES NOW the State of Idaho, by and through the Latah County Prosecuting Attorney, and responds to Defendant's Motion in Limine regarding use of the terms psychopath or sociopath.

Defendant asks this Court to exclude the use of the words " psychopath ” and “ sociopath " during the trial. The State has no plans to use the words “ psychopath ” or “ sociopath ” during the trial based on the current record.

The State notes, however, the defense recently put Defendant's mental health at issue. (See, e.g., Motion to Strike Death Penalty Re: Autism Spectrum Disorder, filed 2/24/25.) As a result,
STATE'S RESPONSE TO DEFENDANT'S MOTION IN LIMINE

# 4 RE: USE OF TERMS PSYCHOPATH OR SOCIOPATH 1

the State may move to have Defendant examined by its own expert. See I.C. § 18-207 (4) (c). If such an examination takes place and reveals any additional information about Defendant's mental health or the defense asserts additional information regarding Defendant's mental health, the State reserves the right to use that information to the extent it is relevant and admissible on the issues of guilt or punishment.

RESPECTFULLY SUBMITTED this 17th day of March 2025.

William W. Thompson, Jr. Jeff Nye Prosecuting Attorney Special Assistant Attorney General
STATE'S RESPONSE TO DEFENDANT'S MOTION IN LIMINE

# 4 RE: USE OF TERMS PSYCHOPATH OR SOCIOPATH 2

CERTIFICATE OF DELIVERY

I hereby certify that true and correct copies of the STATE'S RESPONSE TO
DEFENDANT'S MOTION IN LIMINE # 4 RE: USE OF TERMS PSYCHOPATH OR
SOCIOPATH were served on the following in the manner indicated below:
Anne Taylor Mailed Attorney at Law E-filed & Served / E-mailed PO Box 2347 Faxed Coeur D Alene, ID 83816 Hand Delivered Dated this 17th day of March 2025.

Saeng
STATE'S RESPONSE TO DEFENDANT'S MOTION IN LIMINE

# 4 RE: USE OF TERMS PSYCHOPATH OR SOCIOPATH 3