State v. Chapple

At his trial for first-degree murder, Dolan Chapple (defendant) asserted a single argument in his defense. He argued that he was not the killer because he was in another state at the time of crime. At dispute in the trial was the testimony of Malcolm Scott and Pamela Buck, who testified for the State of Arizona (State) (plaintiff) that Chapple was “Dee,” a person identified by Scott and Buck as present at the scene of the murder. Scott and Buck did not witness the murder, but Buck testified that Dee confessed to the murder, telling her that he had “shot that _____ in the head.” At trial, the State sought to admit into evidence color photos showing the victim’s burned body, face and skull, the gunshot entry wound, and close up images of the charred skull and brain matter where the bullet had lodged. Chapple did not contest the cause of death and offered to stipulate to the cause of death at trial. The court admitted the photos into evidence over Chapple’s objection. Chapple also sought to introduce testimony of Dr. Elizabeth Loftus, an expert on eyewitness identification, that Scott and Buck’s identifications were unreliable. Dr. Loftus planned to testify to general factors regarding eyewitness identifications and the variables affecting memory, including the timing of the identification and the effects of stress and lack of confidence on the witness's identification. Dr. Loftus was not planning to give an opinion specifically on the accuracy of Scott and Buck's identifications. The trial court excluded this testimony. Chapple was convicted and appealed his conviction, claiming that the court erroneously admitted the photos of the victim because the photos were gruesome and inflammatory and prejudiced the jury against him. Chapple also claimed that the trial court abused its discretion in excluding Dr. Loftus's testimony. The case was ultimately appealed to the Arizona Supreme Court.