JONATHAN PHIFER v. STATE OF MARYLAND

Daily Record Staff//June 9, 2020//

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Criminal procedure — Motion to suppress evidence — Cell phone photograph

A jury sitting in the Circuit Court for Baltimore City convicted Jonathan Phifer, appellant, of first-degree murder, use of a firearm in the commission of a crime of violence, possession of a firearm by a disqualified person, and wearing, carrying, or transporting a handgun.

Mr. Phifer raises three arguments on appeal, which we have slightly rephrased for clarity: I. Did the trial court err when it precluded defense counsel from questioning a “State’s witness about whether he hoped for or expected a benefit in exchange for information he provided to the police”? II. Did the trial court err when it admitted into evidence a certain photograph on Mr. Phifer’s cell phone? III. Did the trial court err when it denied Mr. Phifer’s motion to limit the testimony of the State’s firearms expert?

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