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Court of Appeals — Harmless Error: People v. Byer

New York State Court of Appeals 

Harmless Error

Overwhelming Evidence — Inadmissible Statements

People v. Byer
No. 84

Background: The defendant was convicted for murder after he stabbed his girlfriend’s female friend multiple times. It was alleged that he subsequently dismembered her body. The defendant argued inadmissible testimony was introduced at trial prejudicing the outcome. An investigator testified that the defendant said “it wasn’t his first body” and that “there were nine others.” The victim’s nephew testified that the victim had told him that the defendant had threatened to “cut her up.” Finally, a social worker testified that the girlfriend had told the social worker of the defendant’s history of domestic violence.

Ruling: The Court of Appeals held that the admissions were harmless. The proof of the defendant’s guilt was overwhelming and there was no probability that the defendant would have been acquitted had this evidence been excluded.

Bruce D. Austern for the appellant; Justin J. Braun for the respondent