State v. Collins, 763 S.E.2d 22

Bentley Collins was convicted of involuntary manslaughter and three counts of owning a dangerous animal after a ten-year-old boy was killed and partially eaten by dogs in Collins’s yard.
The victim’s body was found among unrestrained dogs with no fencing or containment on Collins’s premises.
Pre-autopsy photographs of the victim were admitted over defense objection to document injuries.
The State argued the photos were probative, corroborating other evidence and aiding the jury in understanding the injuries.
The Court of Appeals reversed and remanded for a new trial based solely on the trial court’s admission of seven pre-autopsy photos; this Court reversed the Court of Appeals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of pre-autopsy photos	Photos were highly probative and corroborative	Photos were unduly prejudicial and violated Rule 403	Admission not abused; photos properly admitted
Harmless error despite admissibility	Photographs contributed to proving elements and defendant’s negligence	Any error were prejudicial and likely affected the verdict	No reversible error; evidence overwhelming; harmless beyond a reasonable doubt

State v. Nance, 320 S.C. 501 (1996) (discretion over admissibility of photographs; Rule 403 balancing)
Turnipseed v. State, 186 Ga.App. 278 (1988) (photos may aid in proving dangerous propensities in criminal negligence cases)
State v. Holder, 382 S.C. 278 (2009) (graphic autopsy photos may be admissible to corroborate pathologist and aid understanding)
State v. Edwards, 194 S.C. 410 (1940) (graphic photo admissibility where depicted facts testified to by witnesses)