State v. Hudson, 380 P.3d 1025

Defendant stabbed neighbor Salomon during a street altercation; Salomon died from a stab wound that perforated his aorta. Defendant claimed he acted in self-defense, saying Salomon choked him from behind. Jury convicted defendant of first-degree manslaughter and acquitted of murder.
Central dispute at trial: whether defendant’s account (stabbing while pinned and reaching behind) was anatomically possible. Medical examiner testified it was unlikely; defense presented Poser-generated computer images and an expert (Knowles) to show possibility.
Prosecution attacked Knowles’ work through its expert (Dovci), who testified Knowles turned off Poser’s anatomical-limits setting and that doing so can produce anatomically impossible poses and distortions. Dovci questioned Knowles’ credibility and motives.
Defense sought to introduce two Poser renderings (a figure scratching its back with limits on vs. off) to show the program’s limits are overly restrictive and to rehabilitate Knowles; the court excluded those renderings as irrelevant.
On appeal, defendant argued the exclusion was legal error and not harmless because the excluded images would have rebutted the prosecution’s attack on Knowles and supported the self-defense theory. The appellate court held the exclusion was erroneous and prejudicial, reversed, and remanded.

Issue	State's Argument	Garrett (Defendant)'s Argument	Held
Admissibility — relevance of Poser renderings showing limits-on vs limits-off	Renderings irrelevant or cumulative; they do not depict the charged act	Renderings rebut prosecution’s claim that turning limits off was deceptive and rehabilitate expert credibility	Exclusion was legal error: renderings were relevant and should have been admitted
Standard of review for exclusion	Treated as discretionary OEC 403 (abuse of discretion)	Trial court excluded as irrelevant (legal error reviewed de novo)	Appellate court found trial court’s ruling was based on relevance and reviewed for legal error
Prejudice/harmless-error of exclusion	Error harmless because other evidence showed Poser limits issue	Excluded evidence was central to defense (not cumulative) and could affect jury’s view of expert and self-defense claim	Error was not harmless; reversal and remand required
Whether excluded evidence was cumulative	Evidence duplicated Knowles’ testimony about Poser limits	Evidence was qualitatively different — visual proof impacting Knowles’ credibility	Court held evidence was not merely cumulative and was qualitatively different

State v. Titus, 328 Or. 475 (standard of review for relevance determinations)
State v. Barone, 329 Or. 210 (low threshold for probative value/relevance)
Fugate v. Safeway Stores, Inc., 135 Or. App. 168 (evidence need not be persuasive to be probative)
State v. Johnson, 225 Or. App. 545 (assessing excluded evidence in light of record)
State v. Richards, 263 Or. App. 280 (central factual issues increase likelihood of prejudice)
State v. Marrington, 335 Or. 555 (prejudice inquiry context)
State v. Bradley, 253 Or. App. 277 (when evidence is cumulative vs qualitatively different)
State v. Davis, 336 Or. 19 (harmless-error standard for evidentiary rulings)