United States v. Collins

A federal jury convicted Joe Lewis Collins (defendant) of conspiracy to commit murder and murder of a government witness, Clovis Reed. The prosecution’s (plaintiff) theory was that Collins and his coconspirators killed Reed so that Reed could not testify against the group in an upcoming fraud-conspiracy trial. Collins and his coconspirators later cut off Reed’s head and hands and dumped Reed’s body, clad only in underwear, in a clearing surrounded by trees. The prosecution presented six photographs of Reed’s body throughout the trial. The prosecution introduced two crime-scene photographs alongside the testimony of Luther Crownover, a beekeeper, that he initially thought Reed’s body was an animal carcass when he discovered it and that the area was marshy and at least a quarter of a mile from houses. The prosecution admitted four autopsy photographs through the testimony of Dr. Hayne, a medical examiner. One autopsy photograph focused on Reed’s upper back and decapitation wound, and the other three photographs depicted Hayne comparing a Kaiser blade to Reed’s wounds. Hayne opined that somebody probably had used a Kaiser blade to amputate Reed’s head and hands about 36 to 48 hours after Reed died. Because Reed’s head and hands were never found, Hayne could not determine a definitive cause of death. The prosecution also argued that the obviously minimal blood in the crime-scene photographs indicated that Reed was killed and dismembered elsewhere. Collins did not dispute the cause of Reed’s death, but Collins repeatedly emphasized that no physical evidence linked him to Reed’s murder. Collins appealed from his conviction, arguing in relevant part that the trial court had erred by failing to apply Federal Rule of Evidence 403 to exclude the six unfairly prejudicial photographs, particularly because Collins had offered to stipulate—or agree—to the facts reflected in the photographs.