State v. Heath
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The Court of Appeals affirmed the judgment of the court of special appeals reversing Defendant's conviction, holding that the trial court erred in admitting irrelevant evidence and abused its discretion in weighing the proportionality of a statement made by Defendant indicating his intention to sell cocaine, and the error was not harmless.
The trial court weighed the probative value and prejudicial effect of the contested portion of Defendant's previously redacted statement and ultimately admitted the unredacted statement, concluding that defense counsel's remarks triggered the opening the door doctrine. Defendant was ultimately convicted of involuntary manslaughter and second-degree assault. The court of special appeals reversed the trial court's ruling that the door had been opened and held that the trial court's error in allowing the statement into evidence was not harmless. The Court of Appeals affirmed and remanded the case for a new trial, holding (1) the trial court erred when it determined that defense counsel opened the door to admitting Defendant's statement based upon a comment made in her opening statement; and (2) admitting Defendant's statement was legal error and an abuse of discretion.
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