This index compiles case law frequently cited as authority in Maryland appellate court decisions, both reported and unreported. These cases are referenced for their precedential value in shaping Maryland law.
Click on any case to read a summary, its significance in Maryland jurisprudence, and related statutes or appellate decisions.
Click on a letter below.
A
B
C
D
E
F
G
Gimble v. State, 198 Md. App. 610, 18 A.3d 955 (2011)
Issue:
- Did the State violate the defendant’s due process rights by destroying potentially exculpatory evidence
- Was the evidence legally sufficient to support a conviction for drug possession and intent to distribute?
- Did the trial court err in denying the defendant’s requested jury instruction on destruction of evidence?
Rule:
- Under Arizona v. Youngblood, 488 U.S. 51 (1988), destruction of potentially exculpatory evidence does not violate due process unless the defendant can show bad faith by law enforcement.
- A conviction is upheld if, when viewed in the light most favorable to the prosecution, any rational fact-finder could determine guilt beyond a reasonable doubt.
- A trial court is not required to give a missing evidence instruction unless the destruction of evidence was central to the defense and materially impacted the case. See Cost v. State, 417 Md. 360 (2010).
Application:
The court found that the destruction of evidence —including a backpack containing drugs and paraphernalia — was a routine administrative action and not conducted in bad faith.
Although the destroyed evidence was potentially useful, its exculpatory value was not apparent before destruction, and police negligence alone does not establish a due process violation.
The evidence was sufficient to support conviction because the backpack was found near the defendant’s crashed vehicle, and he was the sole occupant, allowing an inference of constructive possession.
The Court also held that the missing evidence instruction was not required, as the destroyed items were not central to the defense and alternative evidence, such as photographs and testimony, was available.
Conclusion:
The Court of Special Appeals affirmed the convictions, holding that there was no due process violation, the evidence was sufficient to support the charges, and the trial court did not abuse its discretion in denying the requested jury instruction.
The case is referenced in:
Green v. State, 127 Md. App. 758, 736 A.2d 450 (1999)
Issue:
(1) Did the trial court err in admitting “other crimes” evidence during Green’s testimony?
(2) Did the trial court abuse its discretion in denying Green’s request to call a witness for rehabilitation?
(3) Did the court err in denying a continuance to obtain medical records?
(4) Was the imposed time limit on closing arguments unreasonable?
(5) Did the reasonable doubt instruction improperly minimize the State’s burden of proof?
(6) Did the trial court err in permitting the State to introduce unnotified evidence of a prior shooting at sentencing?
Rule:
(1) Under Md. Rule 5-404(b), evidence of other crimes or bad acts is inadmissible to prove character but may be allowed for other purposes, provided it is relevant and not unduly prejudicial.
(2) The trial court has broad discretion in determining the admissibility of witness testimony and the necessity of a continuance.
(3) Reasonable limitations on closing arguments are within the discretion of the trial court, subject to review only if they are arbitrary or clearly prejudicial.
(4) Jury instructions must be considered as a whole and should not misstate or improperly minimize the State’s burden of proof.
(5) Under Md. Rule 4-342(d), the State must disclose any sentencing evidence to the defense in sufficient time to allow investigation, and failure to do so may require resentencing.
Application:
The Appellate Court of Maryland found no abuse of discretion in allowing testimony about Green’s prior arrest, as it was elicited in response to his own statement about his reluctance to speak with police.
The exclusion of his girlfriend’s testimony was upheld because Green failed to make a proper proffer of its relevance.
The denial of a continuance to obtain medical records was found proper, as the records were not central to the defense, and the delay would have disrupted proceedings.
The Court ruled that a 30-minute time limit for closing arguments was reasonable given the straightforward nature of the case.
The jury instruction on reasonable doubt, while briefly misstated, was properly corrected and did not warrant reversal. However, the court determined that the State’s failure to provide prior notice of the sentencing evidence violated Md. Rule 4-342(d), necessitating a vacated sentence and remand for resentencing.
Conclusion:
The Court affirmed Green’s conviction but vacated his sentence, holding that the failure to provide notice of prior bad act evidence at sentencing violated procedural rules, requiring a new sentencing proceeding.
Key Takeaway for Future Cases:
The ruling in Green v. State (1999) ensures that:
- Prosecutors cannot use “other crimes” evidence in a misleading or prejudicial manner.
- Defense counsel must make a proper proffer when seeking to introduce rehabilitative testimony.
- Requests for continuances must demonstrate necessity and clear prejudice.
- Judges have discretion in managing trial procedures, including time limits on closing arguments.
- Sentencing must follow procedural fairness, and failure to disclose evidence before sentencing may require vacatur and resentencing.
The precedent established in Green v. State, 127 Md. App. 758, 736 A.2d 450 (1999) clarifies several key legal principles in Maryland appellate law:
Limits on “Other Crimes” Evidence: The case reaffirmed that under Md. Rule 5-404(b), prior bad acts or criminal accusations against a defendant are generally inadmissible unless they are relevant to issues other than character, such as motive, intent, or absence of mistake. However, if a defendant opens the door to such evidence (e.g., by making broad claims about their past), the State may introduce limited rebuttal evidence.
Judicial Discretion in Witness Testimony: The decision reinforced that trial courts have broad discretion in determining whether to allow witness testimony, particularly where a party has failed to properly proffer the expected testimony. Failure to make a clear proffer of what a witness would say may result in waiver of the issue on appeal.
Continuances and Trial Strategy: The ruling confirmed that denying a continuance is not an abuse of discretion unless it demonstrably prejudices the defendant. A request for continuance to obtain additional evidence will not be granted if the evidence sought is cumulative or not central to the defense.
- Closing Argument Time Limits: The court upheld the principle that trial judges may impose reasonable time limits on closing arguments as long as they are not arbitrary or prejudicial. The ruling suggests that if defense counsel does not object to a time limit at trial, it cannot be raised on appeal.
- Jury Instruction on Reasonable Doubt: The case underscored that jury instructions must be evaluated as a whole and that minor misstatements do not necessarily constitute reversible error if they are promptly corrected and the overall instruction conveys the correct legal standard.
Sentencing Evidence and Due Process: The most significant procedural precedent from Green is its interpretation of Md. Rule 4-342(d), which mandates that the prosecution must disclose any evidence it intends to introduce at sentencing in advance to allow the defense an opportunity to investigate. The ruling confirmed that failure to provide such notice can warrant resentencing, reinforcing the importance of procedural fairness in sentencing hearings.
This case is particularly useful for criminal defense attorneys in Maryland who need to challenge improper introduction of prior bad acts, request continuances for critical evidence, or contest unfair surprise evidence at sentencing.
The case is referenced in:
H
I
J
K
L
M
N
O
P
Q
R
S
Smith v. State, 232 Md. App. 583 (2017)
Issue:
Did the trial court err in:
(1) Failing to require the jury to find that the defendant intended to threaten the complainant.
(2) Finding sufficient evidence to convict the defendant of threatening a State official.
(3) Admitting testimony that the defendant spat in the direction of the complainant?
Rule:
- A conviction for threatening a State official under Md. Code, Crim. Law § 3-708(b) requires proof that the threat was made knowingly and willfully.
- Sufficiency of the evidence is reviewed in the light most favorable to the prosecution, assessing whether any rational fact-finder could determine guilt beyond a reasonable doubt.
- Evidence is admissible if relevant and not unfairly prejudicial under Md. Rule 5-403, and acts intrinsic to the charged crime do not constitute “other crimes” evidence under Md. Rule 5-404(b).
Application:
The Court held that the jury instructions adequately conveyed the intent requirement, distinguishing Elonis v. United States, 575 U.S. 723 (2015), which applied a negligence standard absent in Maryland law.
The jury was properly instructed that Smith’s threat must be made knowingly and willfully.
The Court further found that Smith’s actions —including his statements, body language, and spitting— provided sufficient evidence for a rational jury to convict.
Lastly, the spitting was admissible as intrinsic evidence, contextualizing the defendant’s threatening conduct.
Conclusion:
The Appellate Court of Maryland affirmed the conviction, holding that the jury instructions met statutory requirements, sufficient evidence supported the conviction, and the admission of the spitting testimony was not an abuse of discretion.
The case is referenced in:
T
U
V
W
Williams v. State, 251 Md. App. 523 (2021)
- Issue: What is the proper standard of review for sufficiency of the evidence on appeal?
- Rule: Appellate courts review evidence in the light most favorable to the State and determine whether any rational fact-finder could have found the essential elements beyond a reasonable doubt.
- Application: The court reaffirmed that it does not reweigh evidence or assess witness credibility but instead evaluates whether the evidence, if believed, meets the required legal threshold.
- Conclusion: The sufficiency of the evidence is upheld if, when viewed in the light most favorable to the prosecution, a rational jury could convict.
The case is referenced in: