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Man Twice Convicted of Murder Wins Third Chance from Top Court

A man twice convicted of murdering his wife will have a third chance to prove his innocence, thanks to an evidentiary misstep at the second trial.The fact that William L. Snyder Sr. never inquired about the progress of the police investigation into his wife’s murder should not have been admitted as evidence of his consciousness of guilt, the Court of Appeals held yesterday.“If consciousness of guilt cannot be inferred from pre-arrest silence, then it would appear that, clearly, it may not be inferred from a failure to inquire,” Chief Judge Robert M. Bell wrote for the court.Such evidence had a special “element of unfairness” in the present case, Bell wrote, because Snyder had cooperated with the police by voluntarily giving exemplars of his fingerprints, hair and blood as requested.“Under these circumstances, [Snyder’s] silence is too equivocal to be probative,” the court held.Kay Snyder was found dead on Valentines Day 1986, on the side of the road across from the home she shared with her husband. Seven years later, William Snyder was tried and convicted of first degree murder by a jury in Baltimore County Circuit Court.That conviction was overturned in 1995 when the Court of Special Appeals found that testimony of the investigating officer was unfairly prejudicial and speculative. He was tried a second time, again was convicted of first degree murder and was sentenced to life imprisonment. The Court of Special Appeals affirmed the second conviction, setting the stage for the top court’s review.Yesterday’s decision was not a complete win for William Snyder, however.At his second trial, the state presented testimony about the couple’s relationship, including a fight that had occurred seven months before the murder and a claim by the couple’s daughters that William Snyder had beaten Kay Snyder at some unspecified date in the past.Circuit Judge Thomas Bollinger Jr. said the evidence amounted to “strands in a cable” or links in the chain of circumstances that showed a “continuing atmosphere as being the motive.”Yesterday, the top court backed him on that decision.“While we agree that a trial court is without discretion to admit a statement that is so remote as to time that its relevance or materiality must rest in conjecture and speculation, under the circumstances of this case, we do not believe the trial court abused its discretion,” Bell wrote.Even if the evidence was not admissible to prove motive, it would have been admissible to rebut William Snyder’s statement to police that his relationship with his wife was “great and getting better,” Bell noted.Judge Dale R. Cathell concurred in the result only.<table width=”100%” border=”0″ cellspacing=”0″ cellpadding=”0″

WHAT THE COURT HELD

Case: Snyder v. State, CA No. 139, Sept. Term 1998. Reported. Opinion by Bell, CJ.; Cathell, J. concurring in result only. Filed Nov. 16, 2000.Issue: In a first degree murder trial, did the judge err in admitting evidence that the defendant had not inquired into the police investigation of his wife’s death as evidence of consciousness of guilt?Holding: Yes; conviction reversed. Given the defendant’s cooperation with police, the evidence that he did not ask about the investigation was too equivocal to be probative.Counsel: Asst. PD Nancy S. Forster for petitioner; Spec. Asst. AG James Gentry for respondent.RecordFax #0-1116-20 (32 pages)