State v. Gallagher
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The Supreme Court vacated Defendant's conviction and sentence for criminal property damage in the second degree, holding that the risk of unfair prejudice posed by the introduction of four prior incidents of aggressive and erratic behavior by Defendant directed at the complaining witnesses and their home substantially outweighed their limited probative value.
Defendant was charged with criminal property damage in the second degree for damaging the complainants' vehicle. During trial, the trial court allowed, over Defendant's objections, the State to introduce evidence of the four prior incidents. The court further permitted the State to adduce evidence of the fear the complaining witnesses experienced experienced as a result of the prior incidents and the countermeasures they undertook in response to the incidents. Defendant was convicted. The intermediate court of appeals affirmed. The Supreme Court vacated the lower courts' judgments, holding (1) the circuit court abused its discretion in its application of Haw. R. Evid. 403; and (2) the court's error was not harmless beyond a reasonable doubt.
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