State v. DiazAnnotate this Case
The Supreme Court affirmed in part and reversed in part the opinion of the court of appeals granting Defendant a new trial on his abduction of a child and statutory rape charges on the grounds that Defendant was prejudiced by the trial court's decision to allow his affidavit of indigence to be admitted to prove his age, holding that the admission of the affidavit was erroneous, but the error was harmless beyond a reasonable doubt.
After Defendant was indicted Defendant completed and signed an affidavit of indigence so that a court-appointed attorney could be assigned to his case. During trial, the trial court allowed into evidence a copy of the affidavit to prove Defendant's age, which was an element of the charges. The court of appeals granted Defendant a new trial, concluding that the trial court erred in admitting the affidavit in violation of Defendant's right against self-incrimination to prove an element of charges against him. The Supreme Court reversed in part, holding (1) the trial court committed constitutional error by allowing Defendant's affidavit of indigence to be admitted into evidence; and (2) there was no reasonable possibility that the admission of Defendant's affidavit of indigence might have contributed to the conviction.