State v. Matthews
Annotate this CaseAppellant Audie Matthews was found guilty by a jury of first-degree murder for a shooting death. When police officers were investigating the shooting, a police dog picked up a "fear scent" near the scene of the shooting and followed the scent through the neighborhood, losing the scent near the location where an officer stopped Matthews for questioning. Matthews appealed, arguing (1) the district court erred in admitting expert testimony that the police dog tracked a fear scent, and (2) the State failed to present sufficient evidence to support his conviction. The Supreme Court affirmed the conviction, holding (1) Matthews failed to establish a reasonable likelihood that the admission of the fear scent testimony significantly affected the verdict under the four factors for harmless error review, and therefore, Matthews was not entitled to a new trial based on the district court's admission of the fear scent testimony; and (2) the alleged shortcomings in the State's evidence did not support a reasonable inference other than that of guilt.
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