State v. EscalanteAnnotate this Case
The Supreme Court reversed Defendant’s drug-related convictions and remanded the case for a new trial, holding that the admission and pervasive use of drug-courier profile evidence during Defendant's trial constituted fundamental error and prejudiced Defendant’s ability to receive a fair trial.
The court of appeals affirmed Defendant’s drug-related convictions and sentences, reviewing for fundamental error whether the trial court correctly admitted the drug-courier profile evidence and hearsay statements. The Supreme Court granted review to clarify what a defendant must show to establish fundamental, prejudicial error. The Court held that to show fundamental error, a defendant must demonstrate that the error goes to the foundation of his case, takes away a right essential to the defense, or is of such magnitude that it denied the defendant a fair trial. To warrant reversal, the defendant must then show prejudice, but if the trial was unfair, prejudice is automatically established. In the instant case, the Court held that Defendant’s trial was infected with fundamental, prejudicial error that deprived him of a fair trial.