Relevance of Autopsy Photos in Homicide and Murder Cases in Arizona

In a criminal case revolving around homicide or murder, it is a long-standing rule in Arizona that photos of the victim’s body are automatically relevant to the proceedings. This rule can be harmful for defendants in these cases, especially in jury trials where jury members will be jarred or emotionally distraught by the photos. In a recent murder case before the Arizona Court of Appeals, Division One, the defendant tried to fight the trial court’s decision to admit photos of an autopsy in his case. His argument ultimately failed, and the higher court reminded him that the photos were automatically relevant because they showed the victim’s body after the murder.

Facts of the Case

The defendant in this case faced criminal charges after an incident outside of a bar one evening. The defendant engaged in a rap battle with another person, which turned violent. The second person removed his shirt and started to approach the defendant. The defendant then immediately pulled out a gun and fired shots in the second person’s direction, hitting him in the face and torso. Paramedics quickly came to the scene but were ultimately unable to resuscitate the individual. The next day, the defendant, who had fled the scene, turned himself into the police.

The State charged the defendant with second-degree murder, and his case went to trial. As part of the proceedings before the trial court, the prosecution introduced photographs of the decedent’s body. At the time, the defendant did not object, but he later argued that the photographs were inappropriately admitted into evidence. The court denied this argument, and the jury found the defendant guilty as charged. The court sentenced the defendant to time in prison.

more State v. Morris

On appeal, the defendant again argued that the court should not have allowed the jury to see the autopsy photos. The photos were not relevant, said the defendant, and they were prejudicial to his case. On appeal, the court disagreed, citing a case called State v. Morris that says that “photographs of a victim’s body are always relevant because the fact and cause of death are always relevant in a murder prosecution.” Because the photos were therefore automatically relevant, the defendant’s appeal had no merit. The court denied the defendant’s appeal and affirmed the conviction for second-degree murder.

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