State v. Triplett, 368 N.C. 172 (Aug. 21, 2015)

Reversing the court of appeals in this murder and robbery case, the court held that the trial court did not abuse its discretion by prohibiting the defendant from introducing a tape-recorded voice mail message by the defendant’s sister, a witness for the State, to show her bias and attack her credibility. Although the court found that the voice mail message was minimally relevant to show potential bias, the trial court did not abuse its discretion in its Rule 403 balancing. Because the sister was not a key witness for the State, any alleged bias on her part “becomes less probative.” The trial court properly weighed the evidence’s weak probative value against the confusion that could result by presenting the evidence, which related to a family feud that was tangential to the offenses being tried.