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Willis v. State

The erroneous admission of hearsay testimony about prior difficulties between defendant and the victim was harmless where defendant denied that he ever threatened or hit the victim.

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Quentin Willis was convicted of the murder of his 18-year-old girlfriend, Tiffany Donovan.1 He contends that the trial court erred in allowing two of the victim’s girlfriends to testify concerning Donovan’s statements about prior difficulties between the defendant and victim when there was direct evidence that was more probative on the issue. Although the hearsay testimony on the prior difficulties should not have been admitted since there was direct evidence about prior acts of violence of similar intensity, the admission of the evidence was harmless. Therefore, we affirm.

1. The evidence presented at trial shows that Donovan, who was right-handed, was shot once on the left side of the head with Willis’s gun. Willis told the 911 operator that he went to the store and when he returned he found that Donovan had shot herself. Police found her lying on her back wearing a shirt, pants, and one sock; her other sock and toenail clippers were under her body. Blood streaks on her face and three separate stains on the mattress cover indicated that her body had been moved. The state’s medical examiner testified that the entry wound shows that the gun’s muzzle was against Donovan’s head when the trigger was pulled. The medical examiner for the defense testified that a press contact wound is found in most suicide cases, but would not be found when there has been a struggle over a gun.

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