State v. Harrison

Summary

The Louisiana Supreme Court held that a photograph obtained from the defendant’s cell phone was admissible as demonstrative evidence because its probative value in identifying the perpetrator outweighed any potential unfair prejudice. The court found that the district court abused its discretion by failing to properly balance relevance against prejudice, reversed the exclusion of photograph “G-1,” affirmed in all other respects, and remanded for further proceedings.

Holdings

1. The district court abused its discretion by excluding photograph G-1 because its probative value in assisting with identification of the perpetrator outweighed any potential unfair prejudice.

Questions Presented

1. Whether the district court abused its discretion by excluding photograph G-1 under Louisiana Evidence Code article 403.
2. Whether photograph G-1 was relevant demonstrative evidence because it could assist the jury in identifying the defendant as the perpetrator.

Disposition

reversed_and_remanded