What is the current state of the law on the admissibility of "gory" photographs of personal injuries?

Trial courts have "broad discretion" under Evidence Code section 352 to weigh the probative value of gruesome or inflammatory photographs against their prejudicial impact. Appellate courts will not disturb this determination on appeal unless one factor clearly outweighs the other. (People v. Scheid (1997) 16 Cal.4th 1, 18, 65 Cal.Rptr.2d 348, 939 P.2d 748.)

One court went so far as to survey cases from "practically every jurisdiction of the United States and Canada dealing with admissibility of photographs of personal injuries," deciding that "[a]ll place determination of the question in the sound discretion of the trial court and most find no abuse." (Twyford v. Weber (Iowa 1974) 220 N.W.2d 919, 926, 927.) Our canvas of case authority paints the same picture; the trial judge is in the best position to balance the competing interests under Evidence Code section 352. The same principles apply whether the debate is over the admission of gory photographs or, as here, their exclusion.