McNaughton v. StateAnnotate this Case
Defendant was convicted of the malice murder and aggravated assault of his wife and sentenced to life in prison. Defendant appealed the denial of his motion for a new trial, asserting that the trial court erred by admitting similar transaction evidence and evidence of statements made by the victim regarding prior difficulties. The court concluded that any prejudice from the age of the similar transactions evidence at issue was outweighed by the probative value of the evidence. The court also concluded that there was no error in admitting the testimony of defendant's cell-mate because the evidence was sufficient to establish the required similarity between the charged crimes and the attack on the cellmate and was probative of defendant's bent of mind and course of conduct. The court did not err in permitting several witnesses to testify about the statements the victim made pertaining to prior difficulties between defendant and the victim where the hearsay testimony was either admissible under the necessity exception to the hearsay rule or its admission constituted harmless error. Accordingly, the court affirmed the judgment.