Appellate panel hears dispute over admission of victim’s letter in Christopher Falls case

An appellate panel heard argument on whether the trial court erred in admitting statements attributed to the victim in the conviction of Christopher Falls, and whether any error was harmless.

Defense counsel told the court that Falls’s conviction should be reversed chiefly because the trial court allowed inadmissible hearsay into evidence. Counsel (identified in the record as Mister Hedrick) pointed to a letter admitted at trial as Exhibit 4 and quoted passages the state later used in closing to describe the defendant as “a dangerous person.” He said the letter and other statements — including a neighbor’s testimony that the victim warned a helper that the defendant “will beat me” — were offered for the truth of their content rather than solely to show the victim’s state of mind, meaning they were hearsay not covered by the state-of-mind exception (Evidence Rule 803(3)), and therefore should not have been used to establish the defendant’s actions.

The defense also asked leave to supplement the record, saying the trial transcript does not clearly show whether the trial judge gave a contemporaneous limiting instruction or why redactions in the admitted letter were made. Counsel argued the remaining forensic proof at trial was limited (no blood or clear transfer evidence), that witnesses described a volatile relationship in which the victim sometimes “gave as good as she got,” and that heavy methamphetamine use could support a lesser theory of the case. On that basis, defense counsel said any hearsay error could be harmful to the verdict.

Ryan Davis, arguing for the state, told the panel the court should affirm the conviction. Davis said three categories of statements at issue were not hearsay: some were direct instructions (for example, the transcript shows a passage where the victim told a friend to notify police if the defendant appeared at her home), and others were admissible to show the victim’s state of mind leading up to her death or to rebut the defendant’s alternative-perpetrator theory raised in opening statements. The state contended the letter’s envelope and final paragraph supported treating it as an instruction, that the letter played only a small part of closing argument, and that the remainder of the circumstantial record — threats heard by neighbors, visible scars on the victim, the defendant’s possession of the victim’s Subaru and personal items (credit cards, Social Security card), the defendant’s flight across states and arrest in Illinois, and statements suggesting he anticipated a lengthy sentence — together provided overwhelming proof of identity and guilt.

A justice pressed whether admitting a victim’s state-of-mind statements to rebut a broad set of defenses would lack a limiting principle; the state cited appellate decisions (including Pearman and earlier Tennessee cases discussed in the briefs) and described the determination as fact-specific. The panel repeatedly asked whether the final jury instructions and any curative limiting instruction are in the appellate record; counsel indicated the instructions are not plainly reflected in the transcript and offered to supplement the record.

During rebuttal, defense counsel argued Pearman and related authority are distinguishable and reiterated that the government had not consistently articulated a single admissibility theory at trial, so the appellate court should reverse and order a new trial.

The panel heard the arguments and did not rule from the bench. The court thanked counsel and called the next case; a written opinion or order will follow the court’s internal deliberations.