State v. McCaleb
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The Supreme Court reversed the judgment of the court of criminal appeals reversing the trial court's ruling that Defendant's statements during a post-polygraph interview were inadmissible pursuant to Tenn. R. Evid. 403, holding that the trial court did not erroneously assess the evidence or incorrectly evaluate the danger of unfair prejudice when determining whether to exclude Defendant's post-polygraph statements under Rule 403.
Specifically, the Supreme Court held that the trial court concluded the Rule 403 balancing test within the parameters of its sound discretion and that the analysis by the court of criminal appeals essentially constituted a reweighing of the evidence before the trial court and a substitution of its judgment for that of the trial court. Because this approach was contrary to the Court's abuse of discretion standard of review, the Court reversed the judgment of the court of criminal appeals and remanded the matter to the trial court for further proceedings.
Court Description:
Authoring Judge: Chief Justice Jeffrey S. Bivins
Trial Court Judge: Judge Barry Steelman
We granted permission to appeal to determine whether the Court of Criminal Appeals misapplied the standard of review applicable to trial court decisions to admit or exclude evidence. In this case, the trial court determined that the defendant’s statements during a post-polygraph interview were inadmissible pursuant to Tennessee Rule of Evidence 403. On interlocutory appeal, the Court of Criminal Appeals concluded that the trial court abused its discretion by excluding the statements. The Court of Criminal Appeals reversed the trial court’s ruling and remanded the matter for further proceedings. We granted the defendant’s application for permission to appeal. We now hold that the Court of Criminal Appeals erred when it concluded that the trial court abused its discretion. Accordingly, we reverse the judgment of the Court of Criminal Appeals and remand this matter to the trial court for further proceedings consistent with this opinion.
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