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WILLIAM WARREN v. STATE OF MARYLAND

Criminal procedure — Jury instructions — Prior statements by state witness

The events concerning the instant appeal involve a September 2014 shooting, in Baltimore City, where Kevin Bass was shot and later died from his injuries. Appellant was tried and convicted by a jury in the Circuit Court for Baltimore City (White, J.) of possession of a firearm by a prohibited individual and two counts of wearing and carrying a firearm. Appellant was sentenced to twelve years’ incarceration, the first five years to be served without the possibility of parole for possession of a firearm by a prohibited individual. The court merged one of the counts of wearing and carrying a firearm with possession of a firearm by a prohibited individual and ordered that appellant serve three years’ incarceration for the non-merged count.

Appellant filed the instant appeal, in which he raises the following questions for our review:

1. Did the trial court err in admitting prior statements made by a witness for the State as substantive evidence?

2. Did the trial court err in instructing the jury that prior statements made by a witness for the State could be treated as substantive evidence?

Read the opinion here: