State v. CanadyÂ, 18-985

On Jan 1, 2014, at a New Year’s party in Columbus County, Keshia Ward was fatally beaten and Johnny Tyler severely injured; both were assaulted in their home in front of children.
Amanda Kay Canady was present and, according to testimony and a short video, participated in beating Ward and Ward’s companion; Ward died of blunt force trauma.
Co-defendants Johnson and Pierce were involved; Johnson pled guilty and agreed to testify; Pierce was previously convicted.
At trial (March 2018) Canady conceded presence but disputed the extent of her role; the State introduced roughly seventy crime-scene and autopsy photographs.
The trial court reviewed photographs in camera, sustained about twenty of Canady’s objections, admitted the remainder, and the jury convicted Canady of first-degree murder, assault with a deadly weapon inflicting serious injury, and attempted first-degree murder.
On appeal Canady argued the photographs were unduly prejudicial under Rule 403 and that their cumulative effect required a new trial; the Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by admitting numerous bloody/gruesome crime-scene and autopsy photographs under Rule 403	Photographs were relevant to illustrate testimony, show manner/extent of injuries, and prove elements of first-degree murder; each photo was considered for its illustrative value	Photos were cumulative, unnecessary to prove Canady’s role, and unfairly prejudicial such that their number and graphic nature outweighed probative value	Court held no abuse of discretion: photographs were reviewed in camera, many objections sustained, admitted photos were probative, and cumulative prejudice was not shown given overwhelming other evidence

State v. Lloyd, 354 N.C. 76 (trial court has discretion under Rule 403; gruesome photos admissible if illustrative, not solely to arouse passion)
State v. Clark, 138 N.C. App. 392 (number and use of photographs evaluated under totality of circumstances)
State v. Hennis, 323 N.C. 279 (no bright line for excess; court must examine content and manner of photographic evidence)