Hayes v. State

In Hayes v. State, 85 S.W. 3d 809, 816 (Tex. Crim. App. 2002), the Court of Criminal Appeals assessed a photo and arguably the most "inflammatory," stating, "Exhibit 19A depicts Rosalyn Robinson's skin pulled back around a grazing gunshot wound to the head, showing the path of the bullet as it passed through her face, fracturing her facial bone and bruising the brain. If the skin were not pulled back, the jury would not be able to see the full extent of one of her fatal injuries. The action of pulling back the skin did not make the evidence significantly more gruesome." The court also found the admission of 19A, if error, was harmless.