Thomas v. State (Ct. of Appeals)

Filed on March 16, 2007. Opinion by Judge Irma Raker.

From the headnotes by the court:

"CRIMINAL LAW – PRELIMINARY PROCEEDINGS – DISCOVERY VIOLATIONS –
SANCTIONS: Under Maryland Rule 4-263, the trial court possesses discretion to impose appropriate sanctions for discovery violations; the proper focus and inquiry in determining the proper sanctions is whether the petitioner was prejudiced, and if so, whether he was entitled to have the evidence excluded.

CRIMINAL LAW – PRELIMINARY PROCEEDINGS – DISCOVERY VIOLATIONS –
SANCTIONS: The trial court did not abuse its discretion in refusing to exclude evidence of consciousness of guilt.

CRIMINAL LAW – EVIDENCE – CONSCIOUSNESS OF GUILT: The State satisfied the evidentiary foundation for the admissibility of evidence of consciousness of guilt."

(synopsis to follow)

The opinion is available in PDF.