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Criminal procedure — Closing argument by state — Burden-shifting language

A jury sitting in the Circuit Court for Baltimore City acquitted appellant Steven Johnson of first-degree murder, but convicted him of conspiracy to commit murder, second-degree murder, use of a handgun in the commission of a crime of violence, carrying a handgun, possession of a regulated firearm by a prohibited person, second-degree assault, and reckless endangerment. The court sentenced him to a total of 80 years of incarceration. He appealed.

Johnson presents the following questions: 1. Did the trial court err in permitting the State to use impermissible burden-shifting language in its closing argument? 2. Did the trial court err in limiting defense counsel’s cross examination of the State’s expert in firearms operability?

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