## Facts

- Benjamin Holley argued briefly with Robert Davis outside 5035 Central Avenue, S.E.; Davis told Holley not to return, and after Holley left Davis said he should “bust” him.
- Davis spoke with Angelo Daniels, and the two left together and met James Campbell, who stopped his white Oldsmobile nearby.
- Davis entered the back seat next to George Terry, Daniels entered the front seat, and Davis directed Campbell to drive so Davis could “do something,” stating he wanted to “wet someone” and “wet the Bama”; Daniels said he was “with” Davis.
- Campbell drove to a location near Holley’s route; Davis and Daniels exited, and Terry saw Davis with a nine-millimeter handgun and what appeared to be a “big gun” under Daniels’s arm.
- Davis and Daniels ran through an alley onto Astor Place where Holley was walking alone; multiple shots were fired, killing Holley.
- The medical examiner found Holley was shot thirteen times, including nine wounds in the back; photographs and wound characteristics suggested shots from more than one gun, including shots when Holley was down.
- At trial, the defense offered to stipulate to the number and placement of the wounds, but the prosecution presented live medical examiner testimony and autopsy photographs over objection.
- Daniels and Campbell were tried jointly and convicted of first-degree murder while armed; Daniels was also convicted of firearm and prohibited-weapon offenses.

## Issues

1. Whether the evidence was sufficient to prove Daniels’s participation as a shooter and to establish premeditation and deliberation for first-degree murder while armed.
2. Whether the evidence was sufficient to convict Campbell as an aider and abettor to first-degree murder while armed based on his role as driver.
3. Whether the trial court erred by permitting medical examiner testimony and autopsy photographs despite the defense offer to stipulate to the underlying facts.
4. Whether admission of challenged testimony and denial of Daniels’s mistrial motion required reversal due to hearsay and resulting prejudice.

## Decision

- The D.C. Court of Appeals affirmed all convictions.
- The court held the evidence permitted a rational jury to find Daniels was a shooter and acted with premeditation and deliberation.
- The court held the evidence permitted a rational jury to find Campbell knowingly assisted the plan and was guilty as an aider and abettor.
- The court held the trial judge did not abuse discretion by allowing the government to present the medical examiner’s testimony and photographs notwithstanding a proposed stipulation.
- The court rejected Daniels’s hearsay and mistrial arguments because the statements were admissible on recognized grounds and, in any event, any error was harmless given the overall proof.

## Legal Principles

- Sufficiency of the evidence is assessed by whether, viewing the evidence in the light most favorable to the government, any rational juror could find the essential elements beyond a reasonable doubt.
- Premeditation and deliberation may be inferred from the sequence and manner of the attack, including pursuit, repeated shots, shots from behind, and shots fired when the victim is down.
- Aiding-and-abetting liability may be found where a defendant knowingly assists and supports the criminal venture; participation can be inferred from conduct facilitating the offense (including transportation) and awareness of the planned violence.
- The prosecution is generally entitled to present evidence of its own choosing and ordinarily cannot be forced to accept a defendant’s stipulation in place of probative proof.
- Autopsy photographs and medical examiner testimony are admissible if their probative value is not substantially outweighed by the risk of unfair prejudice; disturbing content alone does not require exclusion.
- Even if hearsay is admitted in error, reversal is unwarranted if the error did not substantially affect the verdict.

## Conclusion

The court affirmed the convictions because the combined eyewitness, statements of intent, conduct in pursuing the victim, and forensic evidence supported findings of two shooters, premeditation, and Campbell’s knowing assistance, and because the trial judge acted within discretion in admitting autopsy proof and any claimed hearsay did not justify a mistrial or reversal.


Daniels v. United States, 738 A.2d 240 (D.C. 1999)