People v. Coneal
Annotate this CaseConeal, convicted of first-degree murder based on a 2012 shooting, challenged the admission of five rap videos featuring him and/or members of his gang taunting their rivals and bragging about violence. The court of appeal affirmed, holding that the error was harmless. The videos had minimal probative value, either because they were cumulative of other, less prejudicial evidence, or because their probative value depended on construing the lyrics as literal statements of fact or intent without a persuasive basis to do so. This minimal probative value was substantially outweighed by the highly prejudicial nature of the violent, inflammatory lyrics, and the admission of the videos was an abuse of discretion under Evidence Code 352. In light of the substantial other evidence of guilt, however, the error was harmless. Coneal admitted being a member of the gang, to trying to buy a gun, and to being at the scene of the shooting; the gangs’ violent rivalry was well-established. There was no evidence of a third person who could have shot the victim. There was no reasonable probability that, but for the erroneous admission of the videos, Coneal would have received a more favorable outcome. The court also rejected claims of prosecutorial misconduct and ineffective assistance and challenges to the jury instructions and the sentence of life without the possibility of parole. Coneal had turned 18 one week before the shooting.
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