Woodin v. State: Excluding CPS “Substantiation” Opinions and Clarifying Key Criminal Procedure Doctrines in Nevada

I. Introduction

In Woodin (James) v. State, No. 89133 (Nev. Dec. 11, 2025), the Supreme Court of Nevada affirmed a Clark County jury’s conviction of James Woodin on:

One count of sexual assault with a minor under fourteen, and
Two counts of sexual assault with a minor under sixteen.

The opinion, issued as an order of affirmance, addresses a wide array of criminal procedure issues frequently litigated in serious sex-offense prosecutions:

Suppression of statements under Miranda and the voluntariness doctrine, including police deception;
Batson challenges to peremptory strikes of Black jurors;
Alleged prosecutorial misconduct in opening statement and cross-examination;
The corpus delicti rule in sexual assault prosecutions;
The interplay between Nevada’s rape-shield statute and the Summitt exception;
Admissibility and limits of Child Protective Services (CPS) testimony;
Jury instructions on voluntariness and the scope of the sexual assault definition; and
The trial court’s handling of a jury request for the victim’s testimony transcript.

Although the court ultimately found no reversible error, the opinion is particularly notable for its explicit holding that CPS testimony regarding “substantiation” of abuse allegations improperly invades the province of the jury. At the same time, the decision reinforces and applies existing Nevada and federal precedents across a spectrum of criminal procedure doctrines.

II. Summary of the Opinion

The Supreme Court of Nevada, per Chief Justice Herndon and Justice Stiglich, affirmed Woodin’s convictions on every ground raised. The court held:

Motion to suppress:
- Miranda compliance – The officer properly advised Woodin of his rights. Comments made before the warning did not unlawfully “minimize” its importance.
- Voluntariness – Under the totality of the circumstances, Woodin’s statements were voluntary. The officer’s remark that “what we talk about here in this room does not go outside this door” was deceptive but not coercive in the constitutional sense.
Batson challenges: The district court did not clearly err in accepting the State’s race-neutral reasons for striking two Black veniremembers; there was no showing of pretext.
Prosecutorial misconduct:
- Objections to challenged comments in opening and cross-examination were sustained, which was deemed a sufficient remedy.
- Unobjected-to comments and questions did not rise to plain error.
- Allegations that the State mistreated the victim or improperly notified CPS were unsupported by the record.
Corpus delicti: Independent evidence (the victim’s prior statements to his mother and police and some trial testimony) provided a prima facie showing of nonconsensual sexual activity with a minor under fourteen. Thus, the corpus delicti rule was satisfied.
Summitt motion & rape-shield issues: The district court properly excluded evidence of the victim’s prior boundary issues with other siblings. It was not admissible under Summitt to explain sexual knowledge, nor under NRS 48.069 to prove consent, because it was remote and did not involve Woodin.
CPS testimony:
- Testimony explaining CPS investigations, family dynamics, and perceived family alignment with Woodin was relevant and admissible, and not improper character evidence.
- However, allowing testimony that the allegation was “substantiated” was error because it invaded the jury’s role to decide the ultimate fact of whether abuse occurred.
- The error was deemed harmless given the strength of the evidence against Woodin.
Jury instructions:
- Voluntariness instructions tracked the language requested by the defense; any error was invited and not reviewable.
- Including the full statutory definition of sexual assault (which covers penetration by the victim of the defendant) did not introduce an uncharged theory and did not constitute plain error.
Jury’s transcript request: The district court acted within its broad discretion in declining to provide an immediate transcript or full playback of lengthy testimony early in deliberations, instead directing jurors to rely on their recollections and inviting a more specific request, which the jury never renewed.

Having rejected all claims of reversible error, the court affirmed the judgment of conviction.

III. Analysis

A. Precedents and Authorities Cited

1. Interrogations: Miranda, voluntariness, and deception

State v. Taylor, 114 Nev. 1071, 968 P.2d 315 (1998): cited for the basic Miranda rule – custodial statements are inadmissible unless preceded by adequate warnings of the rights to silence and counsel.
Rosky v. State, 121 Nev. 184, 111 P.3d 690 (2005): establishes de novo review of constitutional questions surrounding Miranda and voluntariness, with deference to historical fact findings.
Passama v. State, 103 Nev. 212, 735 P.2d 321 (1987): defines voluntariness as requiring a statement to be the product of a “rational intellect and a free will,” free of physical or psychological compulsion. It also identifies factors relevant to the totality-of-the-circumstances analysis (age, length of questioning, deprivation of food/sleep, etc.).
Chambers v. State, 113 Nev. 974, 944 P.2d 805 (1997): reiterates that voluntariness turns on whether government action overbore the defendant’s will.
Steese v. State, 114 Nev. 479, 960 P.2d 321 (1998): reinforces that appellate courts will not disturb a district court’s voluntariness finding when supported by substantial evidence.
Sheriff, Washoe Cnty. v. Bessey, 112 Nev. 322, 914 P.2d 618 (1996): central to the discussion of police deception. The court in Bessey held that deception is a factor in voluntariness and is permissible so long as the methods used are not reasonably likely to produce an untrue confession, and do not inject “extrinsic considerations” that distort a rational choice to confess.
Holland v. McGinnis, 963 F.2d 1044 (7th Cir. 1992), cert. denied, 506 U.S. 1082 (1993): quoted in Bessey and again in Woodin for the principle that deception is impermissible when it introduces considerations other than the suspect’s guilt/innocence and the evidence.
Lynumn v. Illinois, 372 U.S. 528 (1963): cited as a contrast – threats that a suspect’s children would be taken away or benefits cut off were held to be coercive and rendered the confession involuntary.

2. Jury selection and racial discrimination: Batson line

Batson v. Kentucky, 476 U.S. 79 (1986): foundational case prohibiting race-based peremptory strikes.
Williams v. State, 134 Nev. 687, 429 P.3d 301 (2018): reiterates the three-step Batson framework and the deferential standard of review for a trial court’s finding on discriminatory intent.
King v. State, 116 Nev. 349, 998 P.2d 1172 (2000): used to support the trial court’s finding of no pretext, where no seated jurors shared the same characteristics as the stricken jurors identified by the State.

3. Prosecutorial misconduct and plain error

Valdez v. State, 124 Nev. 1172, 196 P.3d 465 (2008): sets out the two-step misconduct analysis (impropriety and whether reversal is warranted), and the plain-error standard for unobjected-to misconduct: error must be clear from the record and must affect substantial rights.
Hernandez v. State, 118 Nev. 513, 50 P.3d 1100 (2002), quoting United States v. Young, 470 U.S. 1 (1985): emphasizes that convictions are not “lightly overturned” for isolated comments; context matters.
Pantano v. State, 122 Nev. 782, 138 P.3d 477 (2006): stands for the principle that sustaining an objection can be an adequate remedy to improper comments; when the district court sustains the objection, further relief is presumptively unnecessary absent additional prejudice.

4. Corpus delicti of sexual assault

Doyle v. State, 112 Nev. 879, 921 P.2d 901 (1996), overruled on other grounds by Kaczmarek v. State, 120 Nev. 314, 91 P.3d 16 (2004): articulates Nevada’s corpus delicti rule—there must be some independent evidence, beyond a defendant’s extrajudicial statements, that a crime occurred. That evidence can be circumstantial and need not meet the reasonable-doubt standard: a “slight or prima facie” showing is enough.
People v. Alcala, 685 P.2d 1126 (Cal. 1984), superseded by statute on other grounds: cited to support the “slight or prima facie” standard and the use of circumstantial evidence.
People v. Falsetta, 986 P.2d 182 (Cal. 1999): referenced only to note statutory changes in California; not central to the holding.
McNair v. State, 108 Nev. 53, 825 P.2d 571 (1992): reinforces that conflicts in evidence (e.g., inconsistent victim statements) are for the jury to resolve in assessing weight and credibility.

5. Rape-shield law and the Summitt exception

Summitt v. State, 101 Nev. 159, 697 P.2d 1374 (1985): the core authority for an exception to Nevada’s rape-shield protection in cases involving child victims. It permits evidence of a child’s prior sexual experiences only to show that the child has sufficient sexual knowledge to describe acts the child claims the defendant committed, i.e., to rebut inferences that the child could not have fabricated such allegations without experiencing them.
Williams v. State, 134 Nev. at 697, 429 P.3d at 311: explains that the Summitt exception is narrow and cannot be used for general attacks on chastity or credibility.
Chapman v. State, 117 Nev. 1, 16 P.3d 432 (2001): clarifies that a child’s prior sexual experiences may be admitted only where necessary to contradict the jury’s assumption that a young child would be ignorant of such acts absent actual abuse.
Guitron v. State, 131 Nev. 215, 350 P.3d 93 (Ct. App. 2015): underscores that Nevada’s rape-shield statute (NRS 50.090) strongly limits inquiries into a victim’s sexual history, subject to narrow exceptions.
Thomas v. State, 122 Nev. 1361, 148 P.3d 727 (2006): cited for the abuse-of-discretion standard in evidentiary rulings.

6. Relevance, character evidence, and CPS testimony

Atkins v. State, 112 Nev. 1122, 923 P.2d 1119 (1996), overruled on other grounds by McConnell v. State, 120 Nev. 1043, 102 P.3d 606 (2004): affirms that trial courts have broad discretion in admitting relevant evidence.
S. Pac. Co. v. Watkins, 83 Nev. 471, 435 P.2d 498 (1967), quoting McLeod v. Miller & Lux, 40 Nev. 447, 153 P. 566 (1917): establishes that nonexpert witnesses may not testify directly to the “ultimate fact” in the case—doing so invades the jury’s province. This principle underpins the court’s ruling that CPS “substantiation” testimony was improper.

7. Jury instructions, invited error, and plain error

Belcher v. State, 136 Nev. 261, 464 P.3d 1013 (2020): codifies the “invited error” doctrine – a party cannot complain on appeal about an error it induced or requested.
Green v. State, 119 Nev. 542, 80 P.3d 93 (2003): used for the proposition that failure to object to a jury instruction restricts review to plain error.
Jeremias v. State, 134 Nev. 46, 412 P.3d 43 (2018): applies plain-error review to unpreserved claims involving jury deliberation issues.
Miles v. State, 97 Nev. 82, 624 P.2d 494 (1981): acknowledges the wide discretion a trial court holds in dealing with jury requests to replay testimony during deliberations.

B. The Court’s Legal Reasoning Issue by Issue

1. Motion to Suppress: Miranda and Voluntariness

a. Adequacy and effect of the Miranda warning

Woodin argued that the officers undermined the Miranda warnings by “minimizing” their importance. The court, applying Rosky’s de novo standard to the constitutional question, found:

The officer read each right individually.
The officer confirmed Woodin understood each right.
The allegedly minimizing comments were made before the warnings.
The statements did not suggest that the rights were unimportant, but rather clarified that receiving Miranda warnings does not automatically mean one is under arrest.

On these facts, the court concluded that there was no Miranda violation: the warnings were properly given and not negated by the officer’s remarks.

b. Voluntariness and permissible police deception

Under Passama and Chambers, the court evaluated whether Woodin’s will was overborne in light of:

His status as an adult;
The reasonable duration of the interview;
Absence of prolonged or repeated questioning;
No physical punishment or deprivation of food/sleep; and
His understanding of his Miranda rights.

The primary challenge centered on the officer’s assurance: “Listen, dude, what we talk about here in this room does not go outside this door.” The court, relying heavily on Bessey and its adoption of Holland, held:

Police deception is relevant but not automatically coercive.
Deception becomes impermissible when it introduces extrinsic pressures (e.g., threats to children, promises of significant benefits) that distort a rational choice to confess.
Here, the officer’s statement did not threaten external consequences nor promise immunity or secrecy in a legal sense; it did not reasonably suggest that Woodin’s statement would never be used against him.
Thus, the remark did not “overbear” Woodin’s will and did not make his confession involuntary.

The court expressly contrasted this case with Lynumn, where threats to remove a suspect’s children were found to be coercive. In Woodin, the only considerations implicated were Woodin’s own guilt or innocence and the strength of the evidence, consistent with Bessey.

2. Batson Challenges

Two Black veniremembers (Jurors 40 and 179) were struck by the State. The trial court found a prima facie case of racial discrimination, triggering steps two and three of the Batson/Williams framework.

Juror 40 – The State cited:
- Views on interfamilial discipline;
- Relationship with an autistic nephew; and
- Employment with the Clark County School District.
Juror 179 – The State cited:
- Social work background;
- Young age; and
- A brother incarcerated for drug trafficking.

The trial judge accepted these reasons as race-neutral and non-pretextual. On review, the Supreme Court:

Emphasized the “great deference” owed to trial courts on discriminatory intent determinations.
Noted, following King, that no seated jurors had the same combination of characteristics cited as the basis for the strikes.
Found no clear error in the trial court’s determination that the State’s reasons were genuine.

The opinion illustrates the continuing difficulty of prevailing on Batson claims absent pattern evidence or comparative-juror analysis showing disparate treatment of similarly situated jurors of different races.

3. Prosecutorial Misconduct

a. Opening statement and cross-examination

Woodin alleged misconduct in:

Comments about defense counsel’s interactions with the victim during opening statement; and
Cross-examination of the victim’s father, particularly questions about whether the father had engaged in sexual conduct with a sibling.

Applying Valdez:

The trial court sustained defense objections to the challenged comments/questions at the time. Under Pantano, sustaining the objection is ordinarily an appropriate and sufficient remedy, absent further prejudice.
The subsequent question—whether the father “was ever taught not to have sex with a sibling”— was not objected to. The court deemed this an uncomfortable but permissible rebuttal to the defense’s theory that autism requires explicit instruction in social boundaries (including, by implication, prohibitions against incest). Under plain-error review, no reversal was warranted.

b. Treatment of the victim and CPS reporting

Woodin further claimed that the State:

Treated the victim with hostility; and
Improperly reported the family to Child Protective Services.

The Supreme Court found these claims unsupported by the record and declined to find misconduct.

4. Corpus Delicti of Sexual Assault

Under Doyle, Nevada requires some independent evidence that a crime occurred, apart from the defendant’s extrajudicial admissions. This “corpus delicti” showing:

Can be circumstantial;
Need not establish guilt beyond a reasonable doubt; and
Is satisfied by a “slight or prima facie” showing that a crime was committed.

Woodin argued:

The victim’s trial testimony suggested some incidents were consensual;
As to one count, the State did not sufficiently show the victim was under 14 at the time of the sexual conduct.

The court emphasized:

The victim’s prior statements to his mother and police indicated lack of consent;
Some cross-examination answers also suggested non-consent;
Testimony allowed a reasonable inference that at least one act occurred before the victim turned 14.

Once this minimal threshold was met, the jury was entitled to consider Woodin’s admissions along with all other evidence. Under McNair, resolving the tension between earlier statements and trial testimony was a matter of credibility for the jury, not a basis for excluding the statements.

5. Summitt, Rape-Shield Protections, and NRS 48.069

Woodin sought to introduce evidence that, years earlier, the victim had “boundary issues” and engaged in sexual contact with siblings other than Woodin. He argued the evidence was admissible:

Under Summitt to show the victim’s sexual knowledge; and
Under NRS 48.069 to prove the victim’s consent.

a. The Summitt exception

The Supreme Court reaffirmed a narrow reading of Summitt:

Evidence of a child’s prior sexual conduct is allowable only to show that the child’s knowledge of sexual behavior could come from sources other than the alleged assault by the defendant.
It may not be used to impeach credibility through generalized evidence of sexual conduct or “unchastity.”

The court noted that Woodin’s proffered use of the evidence—focusing on “boundary issues” rather than the source of the victim’s knowledge of acts specifically alleged against Woodin— fell outside Summitt’s limited scope. Thus, exclusion was proper.

b. Consent evidence under NRS 48.069

NRS 48.069 permits evidence of a sexual assault victim’s prior sexual conduct to prove consent, but only if the evidence is relevant to that issue. The district court found:

The past sibling conduct occurred years earlier;
It did not involve Woodin; and
It had no logical bearing on whether the victim consented to the acts charged in this case.

The Supreme Court agreed that remoteness and lack of direct connection made the evidence irrelevant to consent under NRS 48.069(3)(a), and thus inadmissible.

6. CPS Workers’ Testimony: Relevance, Character, and Ultimate-Fact Opinions

a. Relevance and character evidence

Woodin objected broadly to CPS testimony as irrelevant and prejudicial. Yet the court found the testimony:

Explained CPS’s investigative steps;
Illuminated the family dynamics; and
Supported the State’s theory that the family was aligned with Woodin rather than the victim.

Under NRS 48.015 (definition of relevance) and NRS 48.035 (balancing probative value and unfair prejudice), the court held the testimony probative and not substantially outweighed by unfair prejudice. Importantly, the CPS witnesses did not testify directly about Woodin’s character or present “propensity” evidence; they did not say he had a trait for sexual misconduct or dishonesty. Thus, NRS 48.045’s general bar on character evidence was not violated.

b. The critical error: “substantiation” of abuse

The Supreme Court drew a sharp line, however, at CPS evidence that the allegations had been “substantiated.” Relying on Watkins and McLeod, the court held:

Nonexpert witnesses may not testify directly to the “ultimate fact” in the case.
A CPS determination that an allegation is “substantiated” is essentially a conclusion that abuse occurred—precisely the question the jury must decide.
Allowing such testimony improperly “invades the province of the jury.”

Despite finding this to be error, the court deemed it harmless in light of the totality of evidence. Nonetheless, the opinion clearly signals that, going forward, CPS “substantiation” opinions are inadmissible as ultimate-fact testimony in Nevada criminal trials.

7. Jury Instructions

a. Voluntariness instruction and invited error

The defense on appeal argued the jury was improperly instructed on voluntariness. But the record showed the instruction given used the exact language requested by the defense. Under Belcher:

A party may not complain on appeal about an error that it invited or induced.
Because Woodin requested the language, any error was “invited” and could not form the basis for reversal.

b. Full statutory definition of sexual assault

The instruction on sexual assault included the whole statutory definition, which covers:

Penetration by the defendant of the victim, and
Penetration by the victim of the defendant.

In Woodin’s case, only the former theory was charged. He argued that including the full definition improperly introduced an uncharged theory.

Because he did not object at trial, the Supreme Court applied plain-error review (Green). It found:

The full statutory text simply gave legal context; it did not explicitly invite the jury to convict under an uncharged theory.
The State never argued that Woodin was guilty because the victim penetrated him.
There was no showing that the jury was misled or that the outcome was affected.

Thus, there was no plain error.

8. Jury’s Request for the Victim’s Testimony Transcript

During deliberations, the jury requested a transcript of the victim’s testimony. The district court:

Noted that the testimony had not yet been transcribed;
Expressed concern about the length of a full playback early in deliberations;
Directed jurors to rely on their recollections and the exhibits, per Instruction 6; and
Left open the possibility of a more specific playback request if the jury refined its request.

The jury did not renew the request and returned guilty verdicts about four hours later. With no defense objection, the Supreme Court again applied plain-error review (Jeremias), invoking Miles for the principle that trial courts have broad discretion in handling such requests. It held the district court acted reasonably and that there was no clear, outcome-determinative error.

C. Impact on Nevada Law and Future Litigation

1. CPS “substantiation” opinions: a concrete evidentiary limit

The clearest doctrinal takeaway is the court’s explicit condemnation of CPS “substantiation” testimony:

Such testimony is now squarely identified as an improper invasion of the jury’s role.
Prosecutors should avoid eliciting CPS conclusions that an allegation is “substantiated” or “founded” and confine testimony to investigative steps, observations, and factual statements.
Defense counsel have a strong basis to object—and, if necessary, seek limiting instructions or mistrial relief—when CPS or similar agencies opine directly that abuse did or did not occur.

While rooted in long-standing “ultimate fact” doctrine (Watkins), Woodin applies that principle specifically to CPS abuse determinations in criminal sex-offense cases, giving practitioners a targeted citation for motions in limine and trial objections.

2. Interrogation practices and police deception

Woodin reinforces that:

Reading Miranda rights thoroughly and confirming understanding remains a powerful shield against suppression challenges rooted in alleged “minimization.”
Officers may, within limits, downplay the significance of Miranda warnings (e.g., clarifying that receiving the warning does not mean arrest) without undermining their validity.
Deception—such as implying that “what we talk about here doesn’t leave this room”—will often be treated as non-coercive if it does not introduce extrinsic threats or promises akin to those in Lynumn.

Defendants challenging confessions will need to marshal evidence that deception affected the suspect’s perception of external consequences (e.g., family, benefits, sentencing) rather than just the evidence against them.

3. Rape-shield protections and the narrowness of Summitt

Woodin continues Nevada’s trend of strictly enforcing rape-shield protections:

Siblings’ prior sexual boundary issues, remote in time and unrelated to the defendant, are not admissible simply to cast doubt on a victim’s credibility or sexual morals.
The Summitt exception remains limited to explaining a child’s sexual knowledge in a way specifically tied to the allegations against the defendant.
NRS 48.069’s consent exception requires a direct and logical connection between the prior sexual conduct and consent to the charged acts.

This framework constrains defense strategies that rely on broad inquiries into a minor victim’s sexual history.

4. Practical lessons on objections, invited error, and preserving issues

The opinion is also a cautionary tale about preservation:

Where the trial court sustains an objection, appellate courts are reluctant to find further reversible prejudice.
Failing to object (to misconduct, to jury instructions, or to the handling of jury requests) relegates defendants to the difficult plain-error standard.
Requesting a particular instruction (as with voluntariness here) forecloses appellate attack under the invited-error doctrine.

For practitioners, Woodin underscores the importance of:

Timely, specific objections;
Requests for curative instructions or mistrials where warranted; and
Careful vetting of defense-requested jury instructions for potential appellate consequences.

IV. Complex Concepts Simplified

Miranda warning: The advisement that suspects must receive before custodial interrogation: the right to remain silent, that anything said can be used against them, the right to an attorney, and that an attorney will be appointed if they cannot afford one. Without proper warnings, statements are generally inadmissible.
Voluntariness of confession: Even if Miranda rights are given, a confession must be made freely, without overbearing police pressure. Courts look at all circumstances—age, intelligence, duration of questioning, and presence of threats or promises.
Police deception: Officers may sometimes lie about evidence or make misleading statements. Deception is allowed unless it is so coercive that it is likely to produce a false confession or introduces powerful external pressures (e.g., threats about losing children).
Batson challenge: A claim that a prosecutor used peremptory strikes to remove jurors based on race (or another protected class). The three steps: (1) Defendant shows circumstances suggesting discrimination; (2) Prosecutor gives race-neutral reasons; (3) Judge decides whether those reasons are genuine or a pretext.
Prosecutorial misconduct: Inappropriate actions or comments by prosecutors (e.g., improper arguments, comments on silence). Not every misstep leads to reversal; the question is whether it seriously affected the trial’s fairness.
Plain error: An obvious error on the face of the record that was not objected to at trial but is so serious that it affected substantial rights or resulted in a miscarriage of justice.
Corpus delicti: Literally “body of the crime.” Before using a defendant’s out-of-court confession to convict, the State must show some independent evidence that a crime actually occurred. That showing can be minimal, but it must exist.
Rape-shield law: Statutes (like NRS 50.090 and NRS 48.069) that limit evidence of a sexual assault victim’s prior sexual behavior. The idea is to prevent unfair attacks on the victim’s character unrelated to whether the defendant committed the crime.
Summitt exception: A narrow exception allowing evidence of a child victim’s prior sexual experiences only to explain how the child could know about sexual acts he or she describes, and not to portray the child as promiscuous or untruthful in general.
Character evidence: Evidence offered to show that a person has a certain trait (e.g., violent, dishonest) and acted in accordance with that trait. Generally inadmissible to prove conduct in a specific instance, subject to numerous exceptions.
“Province of the jury” / ultimate fact testimony: The jury—not witnesses—decides the ultimate legal and factual questions (e.g., did the defendant commit abuse?). Witnesses may describe facts and expert opinions, but they may not typically state that “the defendant is guilty” or that an allegation is “substantiated,” as that usurps the jury’s function.
Invited error: When a party affirmatively asks the court to do something (such as give a particular instruction), the party generally cannot later claim that this was error on appeal.

V. Conclusion

Woodin v. State is a comprehensive application of Nevada criminal procedure law in the context of a sensitive sexual assault prosecution. While most of the court’s holdings reaffirm settled principles, the opinion meaningfully clarifies and emphasizes that:

CPS “substantiation” of abuse allegations is inadmissible ultimate-fact testimony that improperly invades the jury’s role, though other contextual CPS evidence may be admitted; and
Police deception in interrogations, while a factor in voluntariness analysis, is not per se coercive and remains permissible so long as it does not introduce extrinsic threats or promises likely to produce false statements.

The decision also confirms the narrow scope of the Summitt exception to Nevada’s rape-shield laws, the difficulty of overturning convictions on Batson or prosecutorial misconduct grounds absent preserved objections and clear prejudice, and the strong deference accorded to trial courts on evidentiary rulings and responses to jury requests.

For practitioners, Woodin serves both as a doctrinal guide and a practical reminder: careful preservation of objections, precise framing of evidentiary motions (especially regarding CPS testimony), and strategic handling of jury instructions are crucial in safeguarding clients’ rights and shaping the record for meaningful appellate review.