STATE OF TENNESSEE v. ELMI ABDULAHI ABDI - Articles

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Posted by: Tanja Trezise on Mar 2, 2015

Court: TN Court of Criminal Appeals

Attorneys 1:

Elaine Heard, Nashville, Tennessee, for the appellant, Elmi Abdulahi Abdi.

Attorneys 2:

Herbert H. Slatery, III, Attorney General and Reporter; Brent C. Cherry, Senior Counsel; Victor S. Johnson, III, District Attorney General; and Rachel Sobrero, Assistant District Attorney General, for the appellee, State of Tennessee.

Judge(s): HOLLOWAY

In this delayed direct appeal, the Defendant, Elmi Abdulahi Abdi, argues that the trial court erred when it admitted a redacted version of his video-recorded statement into evidence. The Defendant contends that the trial court should have introduced the full video-recorded statement to allow the jury to consider his statement in context. The record does not include the un-redacted video statement, a transcript of the audio of the un-redacted video statement, a transcript of a hearing on the Defendant’s motion in limine to exclude the redacted statement, or an order from the trial court ruling on the motion in limine. Additionally, the Defendant did not make a contemporaneous objection when the redacted video was played to the jury and did not require the introduction of the un-redacted video pursuant to the rule of completeness, Tennessee Rule of Evidence 106. We conclude that the trial court did not err in admitting the redacted video and affirm the judgment of the trial court.

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