State v. Chapple case brief

State v. Chapple (Ariz. 1983) 

514 U.S. 1101, 115 S. Ct. 1835, 131 L. Ed. 2d 754 (1995 U.S.)

FACTS

Graphic photographs of murder victim
Δ on trial for a murder where the body was burned; prosecutor witnesses will testify that “Dee” murdered the victim, and that Δ is “Dee;” one witness will testify that Dee said he shot the victim in the head; prosecutor wants to introduce photographs that show the shot in the head – District court judge allows the photographic evidence.

ISSUE

Was it an abuse of discretion of trail judge to allow evidence?

HOLDING

Yes, danger of unfair prejudice was so great that it was an abuse of discretion

Note: this is probably an atypical view – most courts would be give more deference to trial judge’s gatekeeping decision

Also note: photographs weren’t necessary to prove the point in question

Cases where photographs would be necessary to prove controverted fact: to prove the corpus delicti, to identify the victim, to show nature and location of fatal injury, to help determine degree of atrociousness of the crime, to corroborate state witnesses, to illustrate/explain testimony, and to corroborate state’s theory of how and why the homicide was committed