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Due Process – Exculpatory Evidence – prosecution witness’s understating number of prior convictions – harmless error

State v. Robert Carnemolla, 229 Wis.2d 648, 600 N.W.2d 236 (Ct. App. 1999)
For Carnemolla: Robert T. Ruth

Holding: A state’s witness testified that he had two priors, when in fact he had three. The court finds any error harmless, stressing that the witness was a prison inmate and testified in prison clothes – therefore the jury necessarily knew in any event that he’d been convicted of a serious crime.

The court seems to assume the existence of error, but doesn’t discuss its nature, which is probably the state’s due process obligation to ensure accurate information and/or its duty to turn over exculpatory material.

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