State v. Martin Essentials

Stipulation 3

Both parties agree Rob Armstrong died on April 6th, 2025. Both parties also agree that Rob Armstrong did not commit suicide

Stipulation 4

Both parties agree that neither Rob Armstrong nor Charlie Martin experienced sexual assault or domestic violence

Stipulation 6

Both parties agree that the affirmative defense of duress is not a valid defense for murder

Stipulation 7

Both parties agree that all statements recorded via transcripts in this case were said by the person listed as the speaker of that statement. Both parties also agree that the transcripts are accurate reflections of the recorded conversations

Stipulation 8

Both parties agree that in the episode 9 challenge, Rob Armstrong's assigned color was blue

Stipulation 9

Both parties agree that Exhibit 5, the written recollection of what occurred underwater on April 6, 2025 as part of the Episode 9 challenge, is a truthful and accurate description of what occurred

Stipulation 10

Both parties agree to waive all objections to the admissibility of Exhibits 9, 10, 11, 12, 13, 21. Both parties further agree that these exhibits may be admitted into evidence during the case in chief of either part

Stipulation 11

Both parties agree that Exhibits 1, 8, 17, 22, are preadmitted as evidence without objections and may be referenced at any time during the trial starting with opening statements

Stipulation 12

Both parties agree that Exhibit 2 (Episode Guide), Exhibit 15 (Casting List, Season 10), and Exhibit 16 (Past Season Winners) truthfully and accurately describe the information contained therein

Stipulation 15

Exhibit 14 is a Material Safety Data Sheet (MSDS) for Oxalic Acid from the Midlands Product Safety Commission. A PDF version of this document was lawfully recovered from Charlie Martin's personal cell phone. An analysis of the document's metadata by digital forensic technicians determined that the PDF document was downloaded and saved on Martin's personal cell phone on January 8, 2025 at 9:46 am

Stipulation 16

Both parties agree that Charlie Martin's personal cell phone was not used at any point between February 1 and April 7

Stipulation 17

Both parties agree that Exhibit 19 contains text messages between Riley Kaye and a phone number that was a "dumb phone." A "dumb phone" can only make phone calls and send SMS messages; it does not have access to data service or the Internet. The Parties further agree that only the text messages in Exhibit 19 were sent or received by this "dumb phone" number, and no calls were made or received from or to this phone

Stipulation 18

Both parties agree that prior to this case, the estate of Rob Armstrong filed a wrongful death claim against Selcov Studios. The parties settled prior to trial. While the terms of the settlement shall not be disclosed due to a non-disclosure agreement, that nondisclosure agreement does not limit any witness testimony in this case

Stipulation 19

Both parties agree that if Dr. Atlas Hartley is not called to testify as a witness, then Exhibits 3 and 4 are pre-admitted and may be referenced at any time during the trial starting with opening statements

Orders on Motions and Limine A1a

: This Court finds that the parties may discuss the events of Season 2 pertaining to the relationships between relevant parties. The events of the show five years ago may have relevance as to the motivations or biases of parties and witnesses in the case...Nothing in this ruling prohibits either party from discussing firsthand recollections of this season through witness testimony. That witness testimony may be based on either participating in the show or watching the show on television, subject to other evidentiary objections that might be raised

Orders on Motions and Limine A1b

Witnesses and counsel must refer to the certified redacted transcripts of Season 10 episodes. Both parties should presume that any statements offered in the transcripts will be accessible in video format to the jury during deliberations

Orders on Motions and Limine A1c

The Court finds that the notes of the final challenge are a sufficient substitute for 3 showing the footage of the final challenge during the trial...all parties with direct knowledge of the challenge may describe the challenge during testimony of witnesses and in statements to the jury

Orders on Motions and Limine B1

Defendant must provide the State of Midlands with notice of any intent by Defendant to offer evidence of the character of Defendant or victim pursuant to R. 404(a)(2). Defendant must indicate the specific traits of character intended to be pursued

Orders on Motions and Limine B2

Upon receipt of notice by Defendant that Defendant intends to offer evidence under R. 404(a)(2), the State of Midlands may elect to pursue "preemptive rebuttal evidence" of competing traits during its case-in-chief. If Defendant does not provide notice of its intent to offer R. 404(a)(2) evidence, neither party may introduce such evidence at trial

Orders on Motions and Limine B3

The State of Midlands must, as always, offer similar notice to Defendant regarding its intent to offer any evidence of prior crimes, wrongs, or acts, pursuant to R. 404(b)

Orders on Motions and Limine C

At trial, Defendant's interrogation or Kaye's interrogation may be read onto the record by counsel for either party or through a witness without additional foundation and at any point once the record is open. However, parties may object to particular parts of the interrogation on other evidentiary grounds

Orders on Motions and Limine D

The State argued that the social media posts are not being offered to prove the truth of the matter asserted within each post, and, therefore, cannot be hearsay...Any social media posts admitted into evidence at trial will be admitted with a limiting instruction that they not be taken for the truth of the matter asserted therein but only for notice and the effect on the listener (the defendant)

Orders on Motions and Limine E

The State may not object under MRE 702(b) to the sufficiency of evidence or under 702(c) to the reliability of the methods Dr. Lin used in evaluating the Defendant. The credibility of Dr. Lin's conclusion and underlying facts are always relevant grounds for cross-examination...During the evidentiary hearing on this matter, the Court received sufficient evidence to find that Taylor Jha is an expert in Reality TV production. The Court finds that MRE 702(a), (b), and (c) have been satisfied. As long as Jha's testimony is otherwise admissible pursuant to the MRE, Jha's testimony may be admitted as an expert opinion in Reality TV production, if so offered

Orders on Motions and Limine F1

A witness's description of what they viewed when watching video footage is not hearsay so long as that witness does not testify to statements heard on the video. A witness is allowed to describe what they saw; it is not hearsay. Statements from the video may be objected to as hearsay and will be addressed on an individual basis. Moreover, having a witness describe what they saw on a video does not violate MRE 403. The credibility of the testimony is always relevant grounds for cross examination

Orders on Motions and Limine F2

Hearsay objections were raised by both parties regarding premarked exhibits 2, 15, and 16 that were created by the S.O.S. podcast. Both parties objections are noted for the record; however, the Court denies all hearsay objections to Exhibits 2, 15, and 16. If offered as evidence, and otherwise admissible, these exhibits will be admitted but with a limiting instruction to the jury that these exhibits are being offered for the limited purpose of notice of persons and events that existed on The Saboteurs, and should be read in conjunction with Stipulation 12

Orders on Motions and Limine G

The Defense is prohibited from arguing the affirmative defense of duress. Duress is not a permissible defense in a murder trial. Defense is permitted to argue that the Defendant committed the lesser included offense of negligent homicide, if it so chooses. The Court finds that there are insufficient facts to support an affirmative defense of legal insanity. However, whether the Defendant was experiencing mental impairments that prevented them from having the requisite mens rea to commit murder at the time is an available means of defense to the charges. See State v. Bunker (2025)

State v. Marquez

Defendant charged with offense requiring a mental state of "knowingly" argued that the evidence was insufficient because there was no indication she desired or hoped for a particular result. Held: Conviction affirmed. Although a defendant who acted purposefully or who intended a particular result certainly acted knowingly, MPC § 18-103 makes clear there is no such requirement

State v. Butler

A trial court may not prevent a case of murder from going to the jury under an "extreme reckless murder" theory if the evidence, viewed as a whole, could be reasonably interpreted as showing the type of heightened recklessness that equates to purposeful or knowing homicide

State v. Dawson

Defendant's conviction for reckless murder in a vehicular-homicide case was affirmed because "the facts show[ed] a marked deviation in degree away from the established standards of regard for life and the safety of others that is typically seen in the negligent acts that cause most vehicular homicides."

State v. Barrow

MPC §18-303(A)(2) prohibits the reckless killing of another person under circumstances manifesting extreme indifference to the value of human life. The legal concept behind this version of murder has been described as "death by a thousand cuts." While the Court declines to adopt that phrase as a valid legal doctrine, the concept presented therein is apt. When a defendant commits a series of actions that may not, in and of themselves, evince a specific intent to kill the victim, that defendant can still be found guilty of murder if the cumulative harm of their actions shows an extreme indifference to the value of human life... Clearly, the repeated harmful actions by the defendant show greater culpability than accidental or unintentional poisoning. Because the actions of this defendant were a marked deviation from the standards of a law-abiding person, his actions were reckless, and the repeated injurious acts prove that the defendant manifested an extreme indifference to the value of human life

State v. Durden

Midlands does not recognize "temporary insanity" as a valid legal defense. However, a defendant shall be permitted to present evidence of his mens rea at the time of the offense, subject to the MRE... While a defendant shall not argue that he should be acquitted by reason of insanity based on a "temporary insanity" defense, he may present evidence that calls into question his ability to form the requisite mens rea for the charged offense(s), subject to the MRE

State v. Arbuckle

Proving only that a defendant acted in a way that ignored an unjustifiable risk of harm, including loss of life of another, is insufficient evidence of depraved heart murder. That is recklessness. Depraved heart murder requires evidence that (1) the defendant acted reckless and (2) did so in a way that shows the defendant had an extreme indifference towards the value of human life. The most common way in which the State can prove a Defendant violated MPC 18- 303(A)(2) is by proving the Defendant committed multiple reckless actions that had a high probability of causing severe bodily harm to another. Here there was only one act of recklessness, and it was not sufficient proof of an extreme indifference to life

State v. Bernardi

While that evidence may be used as mitigation evidence, it is not dispositive on culpability. The Defendant's own acts and omissions are still relevant to establish her extreme indifference to human life under MPC 18-303(A)(2). Just because another may have acted with an extreme indifference to human life does not acquit the Defendant of her own bad acts

State v. Teglia

Evidence of 5 recklessness or negligence of others may be relevant to whether the Defendant knew or should have known that her actions or omissions had a high probability of causing severe bodily harm to another person. However, the actions of others are not dispositive on whether the Defendant manifested an extreme indifference to human life when evaluating the Defendant's actions independent of the additional negligent or reckless actions of a third party

State v. Bunker

While temporary insanity is not a viable defense in the State of Midlands, a Defendant is always permitted to present, otherwise admissible, evidence of his inability to form the requisite mens rea. Such "mental impairments" are always relevant because such evidence helps the jury determine whether the Defendant had the alleged mens rea to commit the charged offense

State v. Rich

In a criminal case, the burden is proof beyond a reasonable doubt with respect to each and every element of the charged offense(s). The burden is on the State and never shifts to the defendant

State v. Smith

The State's burden of proof applies to elements, not discrete facts. The question in every case is whether cumulative impact of the otherwise-admissible evidence is sufficient to convince the fact finder beyond a reasonable doubt that the element has been proven

State v. Tamoe

A criminal defendant is never required to present evidence or offer an alternative theory of the crime. If a defendant does so, however, a prosecutor may note the defense's failure to offer evidence in support of its theory of the case. Such comments do not imply that the burden of proof has shifted to the defense, nor do they necessarily constitute an infringement on a defendant's exercise of the right to remain silent

State v. Lazares

Criminal defendants have a constitutionally protected right to refuse to speak with police officers and to decline to testify in their own defense. No prosecutor or witness may comment (expressly or implicitly) on a defendant's exercise of either right or suggest that refusal to testify or termination of a police interrogation demonstrates consciousness of guilt

State v. Chatterjee

If a criminal defendant chooses to testify, the defendant's credibility may be challenged just like that of any other witness. For that reason, it is not "burden-shifting" for a prosecutor to point out during cross-examination or summation that the defense has not produced documents or other evidence to support a theory or argument that has been advanced by the defense. The State may not, however, suggest that a defendant had an affirmative duty to produce any documents in order to be found not guilty

State v. Rittgers

Unlike some jurisdictions, MRE 615 allows for the sequestration of the lead investigating officer in a criminal case if that law enforcement officer is not elected to be the government's representative during pretrial matters

State v. Singh

Venue and identification of the defendant are necessary elements of every criminal prosecution. Because Midlands does not permit motions for acquittal, the defense closing argument is the proper place to bring it to the court's attention that the prosecutor has failed to prove these necessary elements of the charged offense

Ahmed v. O'Keeffe

The reason why the witness failed to respond to questions on cross examination is immaterial. If a witness becomes unable or unwilling to respond to otherwise proper questions on cross examination, the trial court must strike the witness's testimony in its entirety

State v. Nakajima

Under MRE Rule 404, general evidence of a defendant's good character or law-abiding nature is not admissible. However, under Rule 404(a)(1), a criminal defendant may offer certain evidence of a "pertinent" character trait. The requirement that evidence be "pertinent" significantly exceeds the comparably low bar of relevancy. "Pertinence" is a more exacting standard by which the trait itself must directly relate to a particular element or facet of the crime charged

Estate of Hamilton v. Walton

Testimony about a psychological condition does not constitute "[e]vidence of a person's character or character trait," the only evidence excluded by MRE 404(a)(1). The fact that a person suffers from a medically recognized psychological disorder is not character evidence any more than the fact that a person has a physical condition that would make it easier or harder for them to perform a given act

Ellis v. Norton

Testimony about an individual's willingness to strain or "push" themselves mentally, physically, or both to finish a task does not constitute "[e]vidence of a person's character or character trait," the only evidence excluded by MRE 404(a)(1). General discussions of a person's resolve or pluckiness does not constitute improper character evidence

State v. Wiseman

The beyond-a-reasonable-doubt burden does not apply to threshold matters involving the admissibility of evidence. In Midlands, the proponent of evidence need only prove these evidentiary matters by a preponderance of the evidence

Zomerfeld v. Noto

Under MRE 104(a), when evaluating the admissibility of evidence, a trial court is permitted to rely on both admissible and inadmissible evidence. The use of underlying inadmissible evidence does not make that inadmissible evidence admissible. Instead, the court is permitted to consider the underlying inadmissible evidence to assess the admissibility of the offered evidence. In a jury trial, the jury may not always be privy to the underlying facts used to determine what evidence is admissible, but the Court may hear it

State v. Watt

Under MRE 104(a), courts may consider custodial documents, such as clerks' certifications or affidavits of records keepers, when determining the admissibility of other evidence without regard for the admissibility of the custodial document itself. The custodial document typically only addresses preliminary matters of admissibility and is not entered into evidence

Kennedy v. Kennedy-Jones

As long as the proponent of the statement produces evidence that would permit a reasonable jury to find, by a preponderance of the evidence, that a given person made a particular statement, a court assessing admissibility must assume that the statement was made by that person

Ginger v. Heisman

Absent particularized reason to believe that the communication may have been sent by someone else, the fact that an electronic communication (an email, text, or social media post) is listed as coming from a number or account that is either known or purports to belong to a particular person is sufficient foundation that the communication was sent by the person

Davis v. Adams

Trial judges must ensure that any scientific testimony or evidence admitted is not only relevant but reliable. In determining reliability, judges should consider only the methods employed and the data relied upon, not the conclusions themselves. The proponent of the evidence has the burden of proving each section of Rule 702 by a preponderance of the evidence.

Tarot Readers Association of Midlands v. Merrell Dow

In assessing reliability under Rule 702(C), judges should consider whether the theory or technique has been or can be tested, whether it has been subjected to peer review and publication, whether it has a known error rate, and whether it has gained widespread acceptance within the field. These factors, while relevant, are not necessarily dispositive... There is no definitive checklist. Judges must make such assessments based on the totality of the circumstances

Richards v. Mississippi BBQ

Midlands Rule of Evidence 703 does not permit experts to testify or to present a chart in a manner that simply summarizes inadmissible hearsay without first relating that hearsay to some specialized knowledge on the expert's part. The court must distinguish experts relying on otherwise inadmissible hearsay to form scientific conclusions from conduits who merely repeat what they are told. The testimony of the former is admissible; that of the latter is not. Of course, statements that would otherwise be admissible are not inadmissible simply because they are offered by or through an expert witness

State v. Richardson

Unlike other jurisdictions, Midlands does not require a party to "tender an expert" before eliciting an expert opinion. Whether MRE 702 foundational requirements have been satisfied is an evidentiary determination that rests within the sound discretion of the trial court

Kane Software Co. v. Mars Investigations

Midlands does not permit parties to use their experts as weapons in a trial by ambush or unfair surprise. Expert reports that are exchanged prior to trial must contain a complete statement of all opinions the expert will testify to and the basis and reasons for them, the facts or data considered by the expert in forming their opinions, and the expert's qualifications. Experts are strictly prohibited from testifying on direct and redirect examination about any opinions or conclusions not stated in their report, and such testimony must be excluded upon a timely objection from opposing counsel...However, if an expert is asked during cross examination about matters not contained in their report, the expert may freely answer the question as long as the answer is responsive. When an objection is made under Kane Software, the trial court should ask the proponent of the testimony to refer the trial court to where the proposed testimony is contained or otherwise referenced in the expert's disclosure to ensure that the record is clear

Yu-Oh Industries v. Beckstein Alekri Inc.

Experts should not be expected to include in their reports every basic scientific fact known to lay people and known realities of their expertise that support their conclusion. Similarly, experts should not be expected to include in their reports every underlying fact from a specific document so long as the experts explicitly disclosed that they relied upon that document in forming their opinions and that document was made available to the other party through discovery

Jeffries v. Polk County Police Department

Generally, law enforcement officers are not "experts" subject to MRE 702 or this Court's holding in Tarot Readers Association of Midlands v. Merrell Dow (1994) and its progeny. However, law enforcement officers may have specialized training, skills, and experience beyond the average citizen as contemplated in MRE 701 and may testify based on such specialized knowledge. Insofar as a law enforcement officer is asked to provide an opinion based on that officer's general training, skills, and experience as a law enforcement officer (e.g., whether the officer followed standard protocol in collecting evidence), the admissibility thresholds of MRE 702 and Tarot Readers do not apply. Rather, the admissibility of a law enforcement officer's non-expert opinion is subject to the standards of MRE 701 and any other applicable rule of evidence

Omnidirectional Solutions v. Little Bird Word LLC

It was never the intention of this Court for its holding in Tarot Readers Association of Midlands v. Merrell Dow (1994) and its progeny to create a rigid and unyielding standard for expert opinions. So long as the expert can sufficiently explain their expertise, training, and method for review, Tarot Readers Assoc. shall not be used by trial courts to prohibit otherwise credible and admissible opinions simply because there is not a known error rate or prior peer review of the expert's analysis. Such questions and potential challenges of credibility are better left to cross examination

America's Best Cookie v. International House of Waffles

The Court recognizes that practices differ in other jurisdictions. But, in Midlands, the definition of "hearsay" includes out-of-court statements by a witness who is on the stand or by another person who has or will be testifying in a particular trial

State v. Tate

Midlands Rule of Evidence 801(d)(2) may be invoked in only one direction in a criminal case. Specifically, Rule 801(d)(2) permits the State to offer statements by a criminal defendant. Subject to MRE 106, Rule 801(d)(2) does not permit the defense to offer the defendant's own statements, even if the State has already elicited other out-of-court statements by a defendant during a preceding examination

Homel v. Arnzen

For purposes of MRE 801(d)(2), police officers, prosecutors, informants, and others working with law enforcement officials are not an "opposing party" of a criminal defendant

State v. Hilton

MRE 801(d)(2) governs statements "offered against an opposing party." This rule does not require the proponent of the evidence to offer the statement "against the party's interests" in order to qualify as an exemption to hearsay under MRE 801(d)(2) - that language is notably only found in MRE 804(b)(3). If the drafters of the MRE had wanted 801(d)(2) to only apply if the statement was "against the party's interest," it would have drafted the rule as such

State v. Smarda

A witness testifying to their own recollection of what they saw occur on a video recording cannot be hearsay. Here, the defendant's description of what she viewed happening (e.g. people's movements and interactions) during a movie "outtake" video is not hearsay. However, it may be a violation of MRE 802 if a witness testifies to statements they heard or saw on the video depending on whether the statements met the definition of hearsay or if an exception to the hearsay rule applied

State v. Bowling

For statements offered pursuant to MRE 801(d)(2)(E), the proof of the conspiracy need only be shown by a preponderance standard. Given that the Midlands Rules of Criminal procedure do not permit recalling witnesses, the proponent of the evidence may request that a statement be admitted conditionally so that further foundation of the conspiracy can be developed through other witnesses. Whether the evidence will be admitted conditionally is within the sound discretion of the trial court

State v. Desiato

Under traditional common law, a defendant could be found liable for the death of a victim if that victim died within a year and a day from the injury suffered at the hands of the defendant. The idea being that the victim's cause of death was still directly and proximately caused by the defendant within that timeframe. We see no reason to divert from the common law "year plus one day" framework. Held: In a criminal homicide case, the prosecutor must prove, beyond a reasonable doubt, that the defendant's volitional act was the direct and foreseeable cause of the victim's death

State v. Rodgers

Defendant argues that the trial court should not have instructed the jury that he conceded causation when he conceded negligence. The trial court's instruction was proper. It is axiomatic that causation is an element of negligence

Spear v. Vietnam Travel Agency

While Midlands law does not impose an affirmative duty to save others, Midlands law does require someone to protect themselves from obvious harm