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[¶20] Generally, the prejudice required to predicate reversible error is based upon “an undue tendency to induce a decision against the defendant on some improper” ground, “commonly one that is emotionally charged.” State v. Palermo, 168 N.H. 387, 395 (2015) (citation and quotations omitted).

Moreover, we “must assume that the [planning board] made subsidiary findings necessary to support its general ruling.” State v. Palermo, 168 N.H. 387, 394 (2015) (quotation omitted) (addressing trial court ruling); see Rochester City Council v. Rochester Zoning Bd.

“Evidence is unfairly prejudicial if its primary purpose or effect is to appeal to a jury’s sympathies, arouse its sense of horror, provoke its instinct to punish, or trigger other mainsprings of human action that may cause a jury to base its decision on something other than the established propositions in the case.” State v. Palermo, 168 N.H. 387, 395 (2015) (quotation omitted).

We addressed this question in State v. Palermo, 168 N.H. 387, 391 (2015), in which we declined to adopt a heightened standard of authentication after concluding that “our established rules governing authentication [were] sufficient” to address the authentication of Facebook messages in that case.

We addressed this question in State v. Palermo, 168 N.H. 387, 391 (2015), in which we declined to adopt a heightened standard of authentication after concluding that “our established rules governing authentication [were] sufficient” to address the authentication of Facebook messages in that case.

ence, the proponent must produce evidence sufficient to support a finding that the item is what the proponent claims it is.” While “[t]he bar for authentication of evidence is not particularly high,” messages can be authenticated when “the State’s proffered authentication evidence contain[s] sufficient identifying details to link the authorship of the messages to the defendant.” State v. Palermo, 168 N.H. 387, 392-93 (2015) (regarding the authentication of Facebook messages) (quotation omitted).

State v. Palermo, 168 N.H. 387, 397 (2015) (jurors are presumed to follow the court’s instructions).

State v. Palermo, 168 N.H. 387, 394 (2015) (“[W]e must assume that the trial court made subsidiary findings necessary to support its general ruling.” (quotation omitted)).

The decision to admit or exclude evidence is within the discretion of the trial court.

The trial court has discretion whether to admit or exclude evidence.

Although the trial court may not have articulated specific findings of fact in enforcing the subpoena, we ordinarily assume that the trial court made all findings necessary to support its decision.

“The requirement of authentication or identification as a condition precedent to admissibility is satisfied by evidence sufficient to support a finding that the matter in question is what its proponent claims.” State v. Palermo, 168 N.H. 387, 392 (2015) (brackets and quotation omitted).

He contends that the trial court erred by “excluding [his] testimony that [the victim’s] aggressiveness on the night of the allegations indicated to him that [the victim] was intoxicated.” The trial court’s decision to admit or exclude proffered evidence is within its discretion.

“An error is harmless only if it is determined, beyond a reasonable doubt, that the verdict was not affected by the error.” State v. Palermo, 168 N.H. 387, 398 (2015) (quotation omitted).

State v. Palermo, 168 N.H. 387, 394 (2015) (stating that we assume that trial court made subsidiary findings necessary to support its general ruling).

The State bears the burden of establishing that an error is harmless.

403; State v. Palermo, 168 N.H. 387, 394 (2015) (stating that we assume trial court made subsidiary findings necessary to support its general ruling).

The decision to exclude evidence is within the discretion of the trial court.

The decision to admit evidence is within the trial court’s discretion.