California, United States of America
The following excerpt is from People v. Topete, A149801 (Cal. App. 2019):
People v. Johnson (1989) 47 Cal.3d 1194, 1221 [finding that an undated fingerprint on the victim's dresser could not support a murder conviction where the defendant had been the victim's guest, and guesswork as to when the print was made does not elevate speculation to the level of reasonable inference].)
Even if the fingerprint analysis result had marginal relevance, the court acted within its broad discretion in excluding it under Evidence Code section 352. A court's exercise of this discretion " 'must not be disturbed on appeal except on a showing that the court exercised its discretion in an arbitrary, capricious or patently absurd manner that resulted in a manifest miscarriage of justice.' " (People v. Rodrigues (1994) 8 Cal.4th 1060, 1124.) The court was justified in concluding that the limited probative value of this evidence was substantially outweighed by both the likelihood of confusing the issues and the undue consumption of time that its introduction would entail.
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