Yes. The brother's testimony was allowed. Normally, a court wants to see the original video (the 'best evidence'). But there's an exception if the original is destroyed. Since Wood was the one who had the video destroyed, he can't use the 'you must show the original' rule to his advantage. The court just needed to be sure that the brother's story about the video was reliable. The court found it was, for two reasons: 1) the brother knew what Wood and Reneau looked like and could identify them on the video, and 2) the whole reason Wood showed him the video was to prove the murder happened. This context makes the brother's testimony about what he saw believable. So, it was okay for the judge to let the jury hear it.

No, the trial court did not make mistakes. The police testified that Wood understood his rights when he confessed. The witness describing the video knew enough details to make their testimony reliable, even without the actual video. 

The court properly denied the mistrial request about the expert's information, because Wood didn't prove it couldn't be obtained another way or ask for a less extreme solution like delaying the trial. 

Texas' death penalty sentencing process is constitutional. The court didn't do anything wrong in how it handled jury selection or allowing a late expert witness. 

Wood's argument about an unfair legal standard for the 'duress' defense wasn't strong enough. The court also correctly excluded some statements Wood wanted to use in his defense. So the guilty verdict and death sentence stand.

"A mistrial is a device used to halt trial proceedings when error is so prejudicial that expenditure of further time and expense would be wasteful and futile."

A mistrial is required only when the improper question is clearly prejudicial to the defendant and is of such character as to suggest the impossibility of withdrawing the impression produced on the minds of the jurors

A mistrial is an appropriate remedy in "extreme circumstances" for a narrow class of highly prejudicial and incurable errors.

—concluding that trial court did not abuse discretion in denying appellant's motion for mistrial when appellant had not requested less drastic remedy of continuance

Therefore, a trial court properly exercises its discretion to declare a mistrial when, due to the error, "an impartial verdict cannot be reached" or a conviction would have to be reversed on appeal due to "an obvious procedural error."

The trial court is the sole judge of the weight and credibility of the evidence at a suppression hearing.

Among the factors a reviewing court considers in determining whether a trial court abused its discretion by allowing a witness who is not on the State's witness list to testify are (1) whether the State's actions in calling a previously undisclosed witness constituted bad faith, and (2) whether the defendant could have reasonably anticipated that the witness would testify.

"The Equal Protection Clause of the Fourteenth Amendment requires that `all persons similarly situated shall be treated alike'under the law. "Id

"The asking of an improper question will seldom call for a mistrial, because, in most cases, any harm can be cured by an instruction to disregard."

By combining more than one contention in a single issue, an appellant risks rejection on the ground that nothing is presented for review.

Yes. A witness may testify about the contents of a destroyed videotape under these circumstances. The Texas Rules of Criminal Evidence generally require an original recording to prove its content (Rule 1002, the 'best evidence rule'), but Rule 1004 provides an exception. 'Other evidence' of a recording's contents is admissible if the original has been destroyed, unless the proponent of the evidence (here, the State) destroyed it in bad faith. Since Wood, the opponent, instigated the tape's destruction, the State was permitted to prove its contents through other means. Jonathan's testimony served as that 'other evidence.' The testimony was properly authenticated under Rule 901, which can be satisfied through a witness with knowledge (901(b)(1)) or by the 'contents, substance... or other distinctive characteristics, taken in conjunction with circumstances' (901(b)(4)). Jonathan had knowledge because he knew and identified both Wood and Reneau on the tape. Furthermore, the circumstances—Wood playing the tape specifically to prove he and Reneau had just committed the murder he was describing—served to authenticate the tape's contents. Therefore, the trial court did not abuse its discretion in admitting the testimony.

No. The trial court did not abuse its discretion in admitting Wood's confession because the officers' testimony supported the finding that Wood was apprised of his rights and voluntarily waived them. The trial court also did not err in admitting hearsay testimony about the contents of an unauthenticated videotape because the witness was familiar with the individuals and circumstances, which served to authenticate the tape's contents. The trial court properly denied Wood's motion for mistrial regarding the State's expert's undisclosed data because Wood made no showing that the material was unobtainable and did not request a less drastic remedy like a continuance. The Texas death penalty statute's punishment-phase special issues are constitutional and the statute's lack of meaningful appellate review regarding mitigation evidence is not grounds for setting aside the indictment. The trial court did not err in its jury selection procedures or in allowing the State's late disclosure of its expert witness. Wood's equal protection claim regarding the duress defense lacks merit because he failed to show the 'reasonable firmness' standard is not rationally related to a legitimate state interest. Finally, the trial court did not abuse its discretion in excluding Wood's self-serving hearsay statements under the statement-against-interest or excited utterance exceptions. Therefore, the judgment is affirmed.

Jeffrey Lee Wood v. The State of Texas

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