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Michael HoenigMichael Hoenig ()

Joel Stashenko’s informative article in the April 4 Law Journal, “PowerPoints at Trials Must Be ‘Within the 4 Corners of the Evidence’” calls attention to two New York Court of Appeals decisions issued on the same day. In each case, a convicted criminal defendant argued on appeal that the prosecutor’s use, during summation, of PowerPoint slides depicting trial exhibits but upon which were superimposed text, or comments, circles or other matter, was prejudicial. The cases are People v. Williams, 2017 N.Y. LEXIS 766 (April 4, 2017) and People v. Anderson, 2017 N.Y. LEXIS 769 (April 4, 2017). In each case, the state’s highest court affirmed the conviction. However, the court also supplied some much-needed guidance on what permissible boundaries exist when using PowerPoints of trial exhibit images during summation that are not in their unaltered, pristine form.

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