State v. Edwards
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The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder, conspiracy to commit murder, and related crimes, holding that any violation of Defendant's right to confrontation was harmless and that the trial court's third-party culpability instruction was sufficient.
Defendant's convictions arose from a shooting on a crowded street in which a fifteen-year-old boy died and two individuals were seriously injured. The Supreme Court affirmed the convictions, holding (1) as to Defendant's argument that the trial court erred in admitting the out-of-court statements of two witnesses identifying Defendant as the shooter, Defendant failed to preserve his hearsay objection, and even if the admission of the out-of-court identifications violated Defendant's right to confrontation, any error was harmless beyond a reasonable doubt; and (2) the trial court's third-party culpability instruction was sufficient despite the fact that the instruction omitted certain names.
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