People v. Carr-McKnight

Defendant was convicted, after jury trial, of 1st degree murder and home invasion. Pursuant to the one-act, one-crime doctrine, Defendant's conviction for home invasion based on A certain person being the victim, which Defendant was guilty of under theory of accountability for co-defendant's actions. Probative value of allowing jury to consider Defendant's prior crime of dishonesty where her credibility was integral to the jury's resolution of the case was strong. Thus, court properly allowed State to use Defendant's prior theft conviction for impeachment purposes. State's error in asking question of Defendant, on cross-examination rather than in rebuttal as to her theft conviction did not deprive Defendant of substantial justice, and was harmless error. Marital privilege did not apply to statement Defendant made to her spouse while in the presence of a third person, as it was thus not considered confidential. Autopsy photos were relevant as they assisted jury in providing evidence of victim's injuries and internal bleeding.(LAMPKIN and REYES, concurring.)