What is the case law on the admissibility of photographs of crime scene photographs of a murder victim?

"The admissibility of victim and crime scene photographs and videotapes is governed by the same rules of evidence used to determine the admissibility of evidence generally: Only relevant evidence is admissible. [Citations.] The trial court has broad discretion in deciding the relevancy of such evidence. [Citations.]" (People v. Lewis (2001) 25 Cal.4th 610, 641, 106 Cal.Rptr.2d 629, 22 P.3d 392.) In a prosecution for murder, photographs of the murder victim and the crime scene are always relevant to prove how the charged crime occurred, and the prosecution is "not obliged to prove these details solely from the testimony of live witnesses." (People v. Turner (1990) 50 Cal.3d 668, 706, 268 Cal.Rptr. 706, 789 P.2d 887.)

[13 Cal.Rptr.3d 47]

Here, the videotape and the photographs showing the wounds inflicted on the two murder victims and the positions in which their bodies were found in the house were relevant to corroborate and illustrate the testimony of the investigating officers about the condition in which they found the crime scene and to corroborate and illustrate the testimony of the autopsy surgeon about the victims' knife wounds. They were relevant to establish that two murders had occurred and to support the prosecution's theories of premeditation and deliberation and felony murder in the commission of robbery and burglary. "Although defendant contends the photographs were inadmissible because they had no bearing on the only disputed question at trial (his mental state), we have made clear that the absence of a defense challenge to particular aspects of the prosecution's case or its witnesses does not render victim photographs irrelevant. [Citations.]" (People v. Lewis, supra, 25 Cal.4th at p. 641, 106 Cal.Rptr.2d 629, 22 P.3d 392.)

[13 Cal.Rptr.3d 47]

The photographs and videotape were not inadmissible as being cumulative of the witness testimony they were used to illustrate and support. "We have often rejected the argument that photographs of a murder victim should be excluded as cumulative if the facts for which the photographs are offered have been established by testimony. [Citations.]" (People v. Price (1991) 1 Cal.4th 324, 441, 3 Cal.Rptr.2d 106, 821 P.2d 610; accord, People v. Michaels (2002) 28 Cal.4th 486, 532, 122 Cal.Rptr.2d 285, 49 P.3d 1032.) Because the photographs and videotape could assist the jury in understanding and evaluating the witnesses' testimony, the trial court was not required to exclude them as cumulative.