To establish that an error was harmless, the State must prove beyond a reasonable doubt that the erroneously admitted evidence did not affect the verdict. State v. Papillon, 173 N.H. 13, 28, 236 A.3d 839 (2020). An error may be harmless beyond a reasonable doubt if the other evidence of the defendant's guilt is of an overwhelming nature, quantity, or weight and if the improperly admitted evidence is merely cumulative or inconsequential in relation to the strength of the State's evidence of guilt. Id. at 28-29, 236 A.3d 839.
We review the trial court's ruling on the admissibility of evidence for an unsustainable exercise of discretion, and will reverse only if it was clearly untenable or unreasonable to the prejudice of the defendant's case. State v. Papillon, 173 N.H. 13, 24 (2020). In applying our unsustainable exercise of discretion standard of review, we determine only whether the record establishes an objective basis sufficient to sustain the discretionary judgment made.
[11–14] Therefore, to establish harmless error, "the State must prove beyond a reasonable doubt that the error did not affect the verdicts." State v. Papillon, 173 N.H. 13, 28, 236 A.3d 839 (2020). This standard applies to both the erroneous admission and exclusion of evidence.
In making this determination, we consider the alternative evidence presented at trial as well as the character of the erroneously admitted or excluded evidence itself. State v. Papillon, 173 N.H. 13, 29, 236 A.3d 839 (2020).
See id. (finding alleged deficiency in complaint was not shown to constitute plain error where defendant "made no showing, nor even argued, that the complaint limited her ability to prepare for trial or that she would have prepared for trial differently" absent the alleged deficiency (emphasis added)). To the extent the defendant raises other issues in his pro se brief, we conclude that: he has failed to demonstrate that the issues are preserved, see Adams, 169 N.H. at 299, 146 A.3d 1236 ; the issues are inadequately briefed, and therefore waived, see State v. Papillon, 173 N.H. 13, 28, n.1, 236 A.3d 839 (2020) ; or they lack merit and warrant no further discussion, see Vogel v. Vogel, 137 N.H. 321, 322, 627 A.2d 595 (1993). Affirmed.
To establish harmless error, the State must prove beyond a reasonable doubt that the error did not affect the verdict. See State v. Papillon, 173 N.H. 13, 28, 236 A.3d 839 (2020). This standard applies to both the erroneous admission and the exclusion of evidence.
To establish harmless error, the State must prove beyond a reasonable doubt that the error did not affect the verdict. See State v. Papillon, 173 N.H. 13, 28 (2020). This standard applies to both the erroneous admission and exclusion of evidence.
Generally, the harmless error doctrine applies to the erroneous admission or exclusion of evidence at trial and requires the State to prove beyond a reasonable doubt that the error did not affect the verdict. See State v. Papillon, 173 N.H. 13, 28 (2020). Application of this doctrine in the present context requires the State to show that the defendant was not prejudiced by the absence of counsel at the October 2018 hearing.