Koo v. State
Annotate this CaseDefendant was convicted of burglary with a firearm after he removed firearms from the victim’s storage unit. The victim testified at trial that Defendant did not have permission to enter the storage unit without him. After Defendant’s trial, the victim wrote a letter to the trial court purporting to provide a possible motive for Defendant’s action. Defendant filed a motion for new trial asserting that the letter qualified as newly discovered evidence. The trial court denied the motion, concluding that the letter did not constitute a recantation. The court of appeal affirmed, concluding that the letter did not contradict the victim’s trial testimony and did not contain evidence that disproved one of the elements of burglary with a firearm. The Supreme Court affirmed, holding that the trial court did not err in denying Defendant’s motion for a new trial without an evidentiary hearing even though the trial court and court of appeal misstated the appropriate standard for analyzing whether a recantation constitutes newly discovered evidence.
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