Criminal procedure — Motion to suppress evidence — GPS tracking map
Appellant Michael Stratton was convicted by a jury in the Circuit Court for Baltimore County of robbery, second degree assault, and theft between $1,000 and $10,000.
Appellant presents the following questions for our review, which we reorder and rephrase slightly: 1. Did the trial court err in admitting a GPS tracking map where the probative value of that evidence was substantially outweighed by the danger of unfair prejudice to appellant? 2. Did the trial court err in admitting a bank balance screen where that evidence lacked a proper foundation under Maryland’s business records hearsay exception yet was a key piece of evidence that the State needed to prove certain of the crimes charged? 3. Did the motions court err when it denied appellant’s motion to exclude references to shots fired by the police? 4. Did the trial court err in denying appellant’s Motion for New Trial where appellant was prejudiced at trial by repeated references to shots fired by the police? 5. Did the trial court err in admitting a video surveillance video when the State failed to satisfy the chain of custody? 6. Did the cumulative errors of the motions and trial courts deprive appellant of his right to a fair trial?