People v. Safranek

Defendant was charged with five counts of first degree murder and one count of aggravated battery to a child. The State filed multiple motions in limine requesting rulings on the admissibility of certain evidence; some of which the trial court granted and some of which the trial court denied. The contested evidence included internet search history from defendant’s phone, hearsay statements made by the victim, and videos of the victim describing instances of abuse by the defendant. The State filed an interlocutory appeal of the trial court’s adverse rulings. The appellate court affirmed in part and reversed in part, finding that the trial court abused its discretion when it arbitrarily excluded some hearsay statements in part because the court incorrectly concluded that the testimony would be needlessly cumulative. The appellate court further found that the decision to exclude the videos was not an abuse of discretion where their probative value was substantially outweighed by their prejudicial effect and where the evidence was allowed through wintess testimony. (LANNERD and KNECHT, concurring)