Does a defendant have a valid argument that the prosecution was obligated to accept an antiseptic stipulation in lieu of photographic evidence?

Contrary to defendant's assertion, the photographs were relevant to the prosecution's case. Here, the first degree murder charges were tried under the theory that the killings were premeditated or perpetrated during a robbery and burglary. "The photographs were pertinent because they showed the nature and placement of the fatal wounds," and supported the prosecution's theory regarding how the murders occurred. (People v. Pride (1992) 3 Cal.4th 195, 243, 10 Cal.Rptr.2d 636, 833 P.2d 643; see People v. Crittenden, supra, 9 Cal.4th at pp. 132-133, 36 Cal.Rptr.2d 474, 885 P.2d 887.) In addition, the photographs clarified the coroner's and other witnesses' testimony regarding the victims' wounds and the locations in which two of the victims' bodies were found. (People v. Crittenden, supra, 9 Cal.4th at p. 132, 36 Cal.Rptr.2d 474, 885 P.2d 887.) Contrary to defendant's assertion, the prosecution was not obligated to "accept antiseptic stipulations in lieu of photographic evidence." (People v. Pride, supra, 3 Cal.4th at p. 243, 10 Cal.Rptr.2d 636, 833 P.2d 643; see People v. Crittenden, supra, 9 Cal.4th at p. 133, 36 Cal.Rptr.2d 474, 885 P.2d 887.)

Moreover, the photographs were not cumulative. "We often have rejected the contention that photographs of a murder victim must be excluded as cumulative simply because testimony also has been introduced to prove the facts that the photographs are intended to establish." (People v. Crittenden, supra, 9 Cal.4th at pp. 134-135, 36 Cal.Rptr.2d 474, 885 P.2d 887.) The same principle applies to crime scene photographs. While defendant contends the photographs "were cumulative of each other," "depicting essentially the same view of the victims," our review of the record is otherwise. Indeed, the trial court carefully evaluated defendant's objections, the prosecution's response thereto, and the coroner's voir dire testimony, and excluded several photographs on this basis.