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JOSEPH PATRICK SOULE v. STATE OF MARYLAND

Criminal procedure — Voir dire — Burden of proof

Appellant, Joseph Patrick Soule, was convicted in the Circuit Court for Anne Arundel County of second-degree murder and sentenced to thirty years’ incarceration. On appeal before this Court, we affirmed his conviction. Soule v. State, 2019 WL 290600, at *1 (Md. Ct. Spec. App. Jan. 23, 2019), vacated, 2020 WL 995214 (Md. Mar. 2, 2020).

The opinion was based, in part, on the holding in Twining v. State regarding voir dire questions. 234 Md. 97 (1964). On January 24, 2020, the Court of Appeals issued an opinion in Kazadi v. State, No. 11, 2020 WL 398840 (Md. Mar. 2, 2020), wherein the Twining holding was overruled.

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