review I propose looks merely to see whether Idaho's formulation, requiring unnecessary torture, has been consistent. 14 . State v. McKnight, 135 Idaho 440, 19 P.3d 64 (2000) (upholding, in a non-capital case, the trial court's finding that the murder was “heinous, atrocious, or cruel'' because the defendant beat his victim repeatedly with a golf club, causing profuse bleeding, continued to beat the victim with a second golf club, asking his victim if he liked choking on his own blood, and then ran over him with a vehicle at least five times); State v. Wood, 132 Idaho 88, 967 P.2d 702 (1998) (the defendant kept his victim captive for over a day, during which time he sexually molested her and then shot her in the head with a rifle); State v. Porter, 130 Idaho 772, 948 P.2d 127 (1997) (<HOLDING>); State v. Wells, 124 Idaho 836, 864 P.2d 1123
holding that before a defendant is entitled to introduce evidence of the victims character for violence there must be sufficient evidence to support a finding that the victim was the first aggressor and that once the defendant testified that he was attacked and cut by the victim without provocation before using the victims utility tool to stab the victim the defendant was clearly entitled to question the victim about past acts of violence reflected in court documents from the state of oregon holding the harmed victim need not be the victim of the offense of conviction holding that evidence the victim tried to keep defendant from fleeing the scene of a crime and defendant killed victim in order to escape supported the finding that murder was committed to avoid arrest holding that there was sufficient evidence to show that the victim suffered before she died based on numerous bruises on her forearms that appeared to be defensive wounds and the large amount of blood found at the scene of the crime indicating that many of the wounds were inflicted before the victim died holding that emergency medical technicians lay opinion that a victims wounds were caused by a squareheaded or phillips head screwdriver was permissible where technician had previously observed wounds made by screwdrivers and observed the victims wounds as the opinion was one which a normal person who had previously seen puncture wounds made by screwdrivers would form