State v. McKoy

Summary

The court affirmed the defendant’s voluntary-manslaughter conviction, holding that the trial court acted within its discretion in limiting cross-examination about photographs and text messages found on the victim’s phone. Even assuming error, the exclusion was not prejudicial because the evidence could not have affected the defendant’s contemporaneous state of mind and would not reasonably have overcome the evidence that the victim was unarmed and fleeing when defendant fired. The court also limited its review to the issue on which the Court of Appeals panel actually divided.