State v. Harris

The defendant was convicted by jury verdict of the crime of second-degree murder. Her appeal asserts that the trial court erred (1) by failure to grant a mistrial after repeated audience outbursts; (2) by refusing to permit her, on surrebuttal, to present details of a prior violent encounter she had with the murder victim’s older sister; and (3) by improperly instructing the jury on her theory of the defense of justifiable homicide.

We consider first the defendant’s contention that audience disruptions created an atmosphere which demanded a mistrial. Both the defendant and the victim were…