Mattingly v. Commonwealth
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The Supreme Court affirmed the judgment of the trial court convicting Defendant of four counts of first-degree assault and other crimes and sentencing him as a first-degree persistent felony offender (PFO) to forty years' imprisonment, holding that any error was harmless.
Specifically, the Supreme Court held that the trial court (1) did not err when it allowed into evidence a Facebook video from an anonymous tipster allegedly depicting the shooting; (2) did not commit palpable error when it allowed the testimony of Detective O'Daniel, who narrated surveillance video footage; (3) properly allowed Aleisha Courtney's prior identification of Defendant; (4) properly allowed another detective's prior identification of Defendant; (5) improperly excluded evidence of a civil suit by the victims against Defendant, but the error did not likely affect the outcome of the trial; (6) properly allowed Defendant's prior felony convictions at trial and at sentencing; and (7) properly allowed a summary sheet of Defendant's prior convictions that was prepared with certified records. Further, there was sufficient evidence of Defendant's prior felony convictions to support his conviction for possession of a handgun.
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