Summary
applying Kutzen to determine whether the trial court erred in admitting a photograph that was undisputedly the defendant's mug shot, but did not have the common characteristics of a mug shot, while noting that "[i]t is not clear . . . whether the Kutzen test applies to every photograph of a criminal defendant obtained while in police custody or whether it applies only to photographs with some associated indicia of criminal conduct"
Summary of this case from State v. RiveiraOpinion
No. 30206.
November 23, 2010.
Summary Dispositional Orders Affirmed.