- Court: Oregon Court of Appeals
- Area(s) of Law: Criminal Procedure
- Date Filed: 06-09-2021
- Case #: A167177
- Judge(s)/Court Below: Before Ortega, Presiding Judge, and Shorr, Judge, and James, Judge.
- Full Text Opinion
Defendant appealed a conviction for first-degree manslaughter for the death of her child. Defendant assigned error to the trial court’s admission of evidence challenged under OEC 403. On appeal, Defendant argued that the evidence was inadmissible and resulted in unfair prejudice. The evidence in question was video recordings of Defendant behaving inappropriately in front of her children. The evidence was admitted to showcase the environment that the children resided in. Under the Mayfield test, evidence must be logically relevant and have a probative value substantial enough to outweigh any attendant danger of unfair prejudice. Mayfield, 302 Ore. at 645. The court concluded that the trial court abused its discretion because the court improperly evaluated the probative value of the evidence and its prejudicial effect. Reversed and remanded.