Rich v. State

Michael D. Rich, the defendant below, was convicted of sale or delivery of cocaine within one thousand feet of a convenience business and resisting an officer without violence. The defendant appeals the trial court’s decisions to allow evidence and argument regarding the defendant’s use of a racial slur while he was engaged in the sale. We find the trial court’s decisions were harmless errors and affirm.

One white officer and two black officers posed as drug buyers and approached the defendant, who is black, near a convenience business. The white officer asked the defendant for cocaine, but…