Rainey v. State

Summary

The court held that a defendant's change in appearance between a crime and arrest may support a destruction-or-concealment-of-evidence instruction when some evidence supports all four required consciousness-of-guilt inferences. It held that the trial court was not required to state its inference analysis on the record and that the evidence here supported the instruction. Even though a tailored instruction would have been preferable, any instructional error was harmless beyond a reasonable doubt. No separate opinions were filed.