Berry Hall v. Commonwealth of Kentucky

Summary

The Kentucky Supreme Court reversed Hall’s convictions and remanded for a new trial because the trial court admitted an excessive set of highly inflammatory and cumulative crime-scene and autopsy photographs without conducting the required evidence-specific balancing. The Court held that the error was not harmless because the photographs could have substantially influenced the jury’s rejection of Hall’s insanity and extreme-emotional-disturbance defenses. The Court nevertheless upheld the denial of directed verdicts on the four wanton-endangerment charges, concluding that the rifle fire toward the occupied home and the evidence concerning the children’s proximity supported jury consideration. Noble, J., joined by Venters, J., concurred in the reversal but would have directed acquittals on the wanton-endangerment counts and barred retrial on them.