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Authors

Amy S. Thomas

Abstract

In a line of cases, the Utah Supreme Court created a presumption of inadmissibility for gruesome photographs under Rule 403. This presumption is inconsistent with the plain language of Rule 403 and undermines the basic purposes of evidentiary rules: accurate fact-finding and promotion of fairness. The inadmissibility presumption hinders accurate fact-finding by too stringently excluding relevant evidence. The presumption also impedes the promotion of fairness by limiting a prosecutor's ability to introduce photographic evidence in egregious cases. Finally, the court's interpretation makes a biased rule out of a facially neutral rule. To correct these consequences, the Utah Supreme Court should follow the balancing approach to gruesome photographs required by Rule 403's plain language.

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