State v. Ayala

Summary

The court affirmed the defendant’s convictions for murder and conspiracy to commit murder. It assumed, without deciding, that admitting a gang leader’s statement identifying the defendant as the shooter under the coconspirator hearsay exception was erroneous, but held that any error was harmless because the statement was cumulative and corroborated by other evidence and was not emphasized in closing argument. The court also held that testimony about the victim’s fear of the gang was relevant and not unduly prejudicial because the defendant’s relationship with the victim and independent evidence supported an inference of motive. D’AURIA, J., dissenting, would have found the hearsay error harmful and would have reversed for a new trial.