Moreover, by definition, specific instances of prior conduct probative of a witness's character for untruthfulness narrowly include prior instances where the witness lied, made false reports or accusations, or otherwise acted dishonestly, untruthfully, deceitfully, or fraudulently. See State v. Frey , 2018 MT 238, ¶ 20, 393 Mont. 59, 427 P.3d 86 ; State v. Cunningham , 2018 MT 56, ¶ 25, 390 Mont. 408, 414 P.3d 289 (citing State v. Weisbarth , 2016 MT 214, ¶ 21, 384 Mont. 424, 378 P.3d 1195 ). See also State v. Martin , 279 Mont. 185, 198-200, 926 P.2d 1380, 1388-90 (1996) ("certain criminal acts" such as "suppression of evidence, false pretenses, cheating and embezzlement" are probative of "dishonesty" but theft or burglary are not).
We review evidentiary rulings for an abuse of discretion but subject to de novo review of related questions or applications of law. State v. Frey , 2018 MT 238, ¶ 12, 393 Mont. 59, 427 P.3d 86 ; Puccinelli v. Puccinelli , 2012 MT 46, ¶ 12, 364 Mont. 235, 272 P.3d 117. An abuse of discretion occurs if a court exercises granted discretion based on a clearly erroneous finding of fact, an erroneous conclusion or application of law, or otherwise "acts arbitrarily, without employment of conscientious judgment, or exceeds the bounds of reason resulting in substantial injustice." In re D.E. , 2018 MT 196, ¶ 21, 392 Mont. 297, 423 P.3d 586. A finding of fact is clearly erroneous only if not supported by substantial evidence, the court misapprehended the effect of the evidence, or, based on our review of the record, we have a definite and firm conviction that the lower court was mistaken.
We review rulings admitting or excluding evidence for an abuse of discretion. State v. Frey, 2018 MT 238, ¶ 12, 393 Mont. 59, 427 P.3d 86 (noting "broad discretion" of trial courts to determine relevance and admissibility subject to de novo review of related questions or applications of law). A court abuses its discretion if it exercises discretion based on a clearly erroneous finding of fact, an erroneous conclusion or application of law, or otherwise "acts arbitrarily, without employment of conscientious judgment, or exceeds the bounds of reason resulting in substantial injustice." In re D.E., 2018 MT 196, ¶ 21, 392 Mont. 297, 423 P.3d 586 (citing In re D.B., 2007 MT 246, ¶ 16, 339 Mont. 240, 168 P.3d 691). A finding of fact is clearly erroneous only if not supported by substantial evidence, the court misapprehended the effect of the evidence, or, based on our review of the record, we have a definite and firm conviction that the lower court was mistaken.