Teshan Dion Jordan v. State of Maryland

Summary

The Appellate Court of Maryland held that the trial court properly admitted evidence of two additional stolen USPS arrow keys recovered from vehicles linked to Teshan Dion Jordan. The evidence was specially relevant under Maryland Rule 5-404(b) to establish Jordan’s identity, motive for robbing a mail carrier, and distinctive modus operandi in a related mail-theft scheme. The court affirmed Jordan’s convictions.

Holdings

1. Jordan preserved his challenge to the admission of the other-keys evidence by objecting before trial, renewing the objection when the evidence was introduced, and consistently arguing that the evidence suggested he committed other crimes.
2. The two other stolen arrow keys were not intrinsic to the charged robbery and mailbox-theft offenses because those offenses could be fully shown and explained without evidence of the additional keys.
3. The other-keys evidence was specially relevant under Maryland Rule 5-404(b) because it helped establish Jordan's identity as a participant in both the Fowlkes robbery and the related mailbox-theft scheme.
4. Using an arrow key stolen from a USPS mail carrier to repeatedly access mailboxes along the key's associated route was sufficiently unusual and distinctive to constitute a modus operandi relevant to identity.
5. The State established by clear and convincing evidence that Jordan possessed the two other stolen arrow keys.
6. The trial court did not abuse its discretion in determining that the limited other-keys evidence was more probative and necessary than unfairly prejudicial.

Questions Presented

1. Whether Jordan preserved his challenge under Maryland Rule 5-404(b) to the admission of evidence concerning two other stolen USPS arrow keys.
2. Whether the two other stolen arrow keys were intrinsic to the charged offenses.
3. Whether the other-keys evidence was specially relevant under Maryland Rule 5-404(b) to establish Jordan's identity, motive for the Fowlkes robbery, or modus operandi for the mailbox-theft scheme.
4. Whether the State established Jordan's involvement in the other acts by clear and convincing evidence.
5. Whether the probative value and necessity of the other-keys evidence were substantially outweighed by the danger of unfair prejudice.

Disposition

affirmed