Walker v. State, 121 So. 3d 320

Walker was convicted of capital murder and sentenced to life without parole in Copiah County Circuit Court.
During appeal, Walker contends two trial photographs were prejudicial and the court erred in not granting a new trial due to an unreported familial relationship between a juror and a witness.
A juror, Catchings, sat on the jury despite an unrecorded summons; later it was revealed Catchings was related by marriage to Ellis, a proseuction witness.
Post-trial proceedings failed to prove Catchings knew of the relationship; the trial court refused to grant a new trial.
The parties waived objections to Catchings serving on the jury; the court upheld admission of the photographs as probative and not unduly prejudicial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Juror relationship and new trial requirement	Walker argues Catchings withheld information; new trial required	State contends no substantial knowledge; Waiver precludes error	No error; no substantial knowledge shown; no new trial required
Admission of gruesome photographs	Walker argues photos were prejudicial	State asserts photographs were probative and admissible	Photographs properly admitted; probative value outweighs prejudicial effect

T.K. Stanley, Inc. v. Cason, 614 So.2d 942 (Miss. 1992) (juror withholding information; basis for challenge for cause)
Myers v. State, 565 So.2d 554 (Miss. 1990) (challenge for cause standard; voir dire duties)
Odom v. State, 355 So.2d 1383 (Miss.1978) (prong test for new-trial due to juror knowledge)
Chamberlin v. State, 989 So.2d 320 (Miss.2008) (admission of photographs; discretion of trial court)
Dampier v. State, 973 So.2d 221 (Miss.2008) (photograph admissibility; gruesomeness not dispositive)
McNeal v. State, 551 So.2d 151 (Miss.1989) (meaningful evidentiary purpose of photos)
Ramsey v. State, 959 So.2d 15 (Miss.Ct.App.2006) (gruesome photos may be admissible if probative)
Dase v. State, 356 So.2d 1179 (Miss.1978) (photographs may describe circumstances of killing)