State v. Hon. Ronald J. Steinle
Annotate this CaseThe State charged Alejandra Moran with the first-degree murder of L.U., who was stabbed. Moran moved to exclude an excerpt from a cellphone video recorded by a witness to the stabbing on the ground that it was inadmissible under Ariz. R. Evid. 106, 1002, 801 and 901. The witness had cropped the video before it was obtained by the police. The trial court granted the motion. The State sought special action relief, arguing that the excerpt was erroneously excluded because the State was not responsible for the absence of the complete video recording. The court of appeals affirmed. The Supreme Court vacated the suppression order, holding that the trial court erred by precluding the video excerpt based on Rules 106, 1002, 801 and 901. Remanded for consideration of whether the evidence should be precluded under Ariz. R. Evid. 403.
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