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Criminal law — Sufficiency of the evidence — Second-degree child abuse

This case arose out of an investigation by the Caroline County Department of Social Services into allegations that the victim, a minor, had been sexually abused by a family member. Although appellant Erik Carroll was not the initial subject of the investigation, the victim identified him as having abused her. After a bench trial, the Circuit Court for Caroline County convicted Mr. Carroll of two counts of third-degree sex offense, two counts of second-degree child abuse, and two counts of sexual abuse of a minor. The court sentenced Mr. Carroll to a total of 40 years of actual incarceration time on the sexual abuse counts, plus probation, and merged the remaining convictions for sentencing purposes.

Mr. Carroll contends that (1) it was error for the circuit court to deny his motion for a mistrial and (2) the evidence was insufficient to sustain his convictions for second-degree child abuse.

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