State v. Lord

Summary

The Washington Supreme Court held that spectators wearing buttons depicting the murder victim did not inherently prejudice the defendant or deprive him of a fair trial. The court also held that the State satisfied its disclosure obligations regarding private dog-handler evidence and that exclusion of the handler's testimony was within the trial court's discretion because the evidence was not relevant. The court affirmed the conviction.

Holdings

1. Silent spectator displays of affiliation, including buttons showing a victim's photograph without an express message advocating guilt or innocence, do not automatically create inherent prejudice or an unacceptable risk to the defendant's right to a fair trial. The trial court did not abuse its discretion in allowing the buttons for the first three days of trial.
2. The State did not violate Brady or due process by failing to provide additional details about the private dog handler's search or by failing to conduct a further investigation. The disclosed police report sufficiently informed the defense that a private handler had conducted a bloodhound search, and the additional information was only potentially exculpatory and was not shown to have been in the State's possession.
3. The trial court did not abuse its discretion by excluding the dog-handler testimony as irrelevant because the handler could not establish that the scent trail was made on the day Parker disappeared, and the testimony therefore did not make a material fact more or less probable. The majority further concluded that, even if exclusion were error, it was harmless in light of the overwhelming untainted evidence.

Questions Presented

1. Whether spectators' wearing buttons displaying the murder victim's photograph during the first three days of trial created inherent prejudice that denied Lord a fair trial by an impartial jury.
2. Whether the State violated Brady and due process by failing to disclose or further investigate information concerning a private dog handler's search for the victim.
3. Whether the trial court abused its discretion or violated Lord's constitutional right to present a defense by excluding the dog handler's testimony as irrelevant.

Disposition

affirmed