State v. Chapple
Supreme Court of Arizona, En Banc
660 P.2d 1208 (Ariz. 1983)
At his first-degree murder trial, Dolan Chapple (defendant) argued only that he was in another state when the killing occurred and was not the person witnesses knew as "Dee." Two witnesses, Malcolm Scott and Pamela Buck, testified for the state that Chapple was Dee, the man they placed at the crime scene; Buck further testified that Dee had confessed to shooting the victim in the head, though neither witness actually saw the killing. Over Chapple's objection, and despite his offer to stipulate to the cause of death, the trial court admitted graphic color photographs of the victim's burned, gunshot-wounded body, including close-ups of the charred skull and brain matter. The court also excluded testimony from Dr. Elizabeth Loftus, an eyewitness-identification expert who would have described general factors affecting memory and identification accuracy (such as timing, stress, and witness confidence) without opining directly on Scott and Buck's specific identifications. Chapple was convicted and appealed both rulings to the Arizona Supreme Court.
Whether prejudicial evidence that is technically relevant but probative only of an uncontested issue is admissible, and whether expert testimony on eyewitness identification is admissible.