State v. Payne
Annotate this CaseAfter a jury trial, Defendant Leotis Payne was convicted of, inter alia, felony murder, robbery in the first degree, and attempt to tamper with a juror. The Supreme Court affirmed, holding (1) the trial court improperly joined for trial the felony murder and jury tampering cases against the Defendant for trial, but the error was harmless; (2) the trial court improperly admitted the testimony of one of the state's witnesses regarding an alleged threat made by Defendant, but the error was harmless; and (3) three statements by the prosecutor during closing and rebuttal arguments were improper, but those improprieties did not deprive Defendant of a fair trial, and therefore, Defendant was not entitled to a new trial due to the prosecutorial improprieties. In affirming the judgments of the trial court, the Court also overruled State v. King and its progeny, which recognized a presumption in favor of joinder in criminal cases.
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