State v. Massaro

Summary

The court affirmed the conviction because any error in excluding the defense investigator’s memorandum was harmless. The defendant was still able to use the investigator’s account to impeach the principal witness, while substantial physical, testimonial, and corroborating evidence supported the state’s case and the memorandum had questionable reliability. Any error in permitting cross-examination about general characteristics of the narcotics trade was likewise harmless because the testimony was cumulative, did not undermine the investigator’s central testimony, and did not substantially sway the verdict.