State v. JordanAnnotate this Case
The trial court improperly determined that evidence of the victim’s convictions for crimes of violence is inadmissible as a matter of law, but the error was harmless.
Defendant was charged with assault in the second degree by means of a dangerous instrument. Prior to trial, the State filed motion in limine requesting that the trial court preclude evidence of the victim’s criminal convictions, which the State anticipated Defendant would attempt to submit to support his claim of self-defense. The trial court granted the motion, concluding that evidence of the convictions would not be admissible as a matter of law because they occurred subsequent to the charged conduct. The jury rejected Defendant’s claim of self-defense and found Defendant guilty as charged. The Appellate Court affirmed, holding that the trial court abused its discretion by excluding evidence of the victim’s subsequent convictions but that the error was harmless. The Supreme Court affirmed, holding that Defendant did not meet his burden to prove that the exclusion of evidence of the victim’s subsequent convictions was harmful error.