DARRELL BELLARD v. STATE OF MARYLAND
Court of Special Appeals, Nazarian, August 31, 2016,
Murder – Sentencing – Statutory remnants of the repeal of the death penalty did not create a new sentencing procedure that allowed for election of sentencing by jury in 1st Degree Murder trials
UNITED STATES OF AMERICA v. MICHAEL T. RAND
US Court of Appeals for the Fourth Circuit, Gregory, August 26, 2016,
Closing Argument – Prosecutor commentary on defendant’s wealth (“You just heard a story alright. It took a lot of gold. A lot of gold. The defendant’s lawyers, all of them, his experts, a lot of gold.”) was improper, but given the weight of the evidence against the defendant the error was harmless.
ANGELA ANN GRIMM v. STATE OF MARYLAND
Court of Appeals, Greene, Filed May 4, 2016,
Testimony – Antithesis Inference – Discredited non-party testimony “is assigned no weight” and can not be used “in the consideration of the ultimate issue.” (Belief that a non-party witness is lying can not independently support the argument that the opposite is true)
(Dissent – Watts – Witness testimony that they could not remember whether or not they had sex with their step-mother was sufficiently preposterous to support the defendant’s confession)
DEANDRE RICARDO WILLIAMS v. STATE OF MARYLAND
Court of Appeals, Battaglia, Filed Dec. 18, 2015,
Miranda – “I don’t want to say nothing. I don’t know.” held to be ambiguous and insufficient to invoke right to remain silent.
(Dissent: McDonald, Barbera, Adkins – “I don’t know” was a separate statement; didn’t modify “I don’t want to say nothing.” Therefore not ambiguous.)
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