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CHARLES EDWARD SIMMS v. STATE OF MARYLAND

Criminal procedure — Closing argument by state — Preservation of claim

Appellant, Charles Edward Simms, was tried and convicted of first-degree murder by a jury in the Circuit Court for Wicomico County (Beckstead, J.), on March 27, 2017. On June 1, 2017, he was sentenced to life imprisonment.

Appellant filed the instant appeal from this conviction, in which he raises the following questions for our review: 1. Did the trial court err in permitting the State to elicit, through a lay witness, testimony based on specialized knowledge, experience or training? 2. Must Appellant’s conviction be reversed as a result of improper prosecutorial closing argument?

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