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ROBERT ANTHONY ANDERSON v. STATE OF MARYLAND

Appellant, Robert Anthony Anderson, was convicted by a jury sitting in the Circuit Court for Prince George’s County of three counts of armed robbery and lesser included offenses.

Appellant argues that the trial court erred when it refused to categorically exclude the State from admitting into evidence its belatedly disclosed GPS evidence. Appellant argues that the court’s refusal to do so “forced” him to change his defense mid-trial. The State argues that the discovery sanction imposed by the court – prohibiting the State from offering the GPS evidence in its case-in-chief but leaving open the possibility of using the evidence in rebuttal – was consistent with the purposes of the discovery rule, fair to both parties, and ultimately could not have affected appellant’s defense in light of his trial testimony.

Read the unreported opinion.

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