State v. Steen, 2015 ND 66

Steen owned a Williams County property with a garbage dump where Sjol's body was later found after being missing for three weeks with gunshot wounds.
A person connected to Sjol's murder contacted Steen requesting use of the dump and indicated Sjol had been murdered.
Steen discovered Sjol's body and did not voluntarily report it to law enforcement; he also communicated with the person suspected of the murder seeking removal of the body.
Steen was charged with hindering law enforcement after discovery of the body.
Steen moved in limine to exclude photographs of the body; the district court denied the motion and Steen did not object at trial.
Steen appeals the admission of photographs, contending it was error; the district court's ruling is reviewed for preservation and obvious-error standards.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion by admitting photographs.	Steen; the photos were unduly prejudicial and duplicative.	Steen; admission violated rules on prejudice and relevance.	No clear deviation; no obvious error; district court did not abuse discretion.

State v. Anderson, 2003 ND 30 (2003 ND 30) (preservation requirement and waiver for evidentiary objections)
State v. Olander, 1998 ND 50 (1998 ND 50) (obvious error standard under N.D.R.Crim.P. 52(b))
State v. Tresenriter, 2012 ND 240 (2012 ND 240) (definition of obvious error and deviation from legal rule)
State v. Glass, 2000 ND 212 (2000 ND 212) (cautious use of obvious-error review)
State v. Ash, 526 N.W.2d 473 (1995 ND 473?) (standard for using obvious-error review)