South Carolina v. Collins
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Respondent Bentley Collins was convicted of involuntary manslaughter and three counts of owning a dangerous animal causing injury to a person after a ten-year-old boy was killed and partially eaten by his dogs, most of whom were pitbull mixes. The State appealed the Court of Appeals' decision reversing and remanding the case for a new trial based solely on the trial court's admission of seven pre-autopsy photos of the victim. The State argued that the Court of Appeals: (1) failed to give due deference to the trial court's decision; (2) erred in finding that photos entered into evidence were more prejudicial than probative; (3) erred in finding the photos were not material to the elements of the offenses charged and corroborative of other evidence; and (4) erred in making a purely emotional decision to reverse and remand for a new trial. The Supreme Court agreed and reversed the appellate court's decision.
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