Lee v. State, 198 Md. 383

Summary

The Maryland Court of Appeals affirmed convictions for unlawful possession of lottery records and numbers. The court held that the search warrant and supporting affidavit did not need to be formally admitted at trial because the trial court had previously reviewed them, and that the affidavit established probable cause. The court also held that the evidence supported convictions based on lottery records dated January 1 and January 8, 1951.

Holdings

1. The search warrant and affidavit did not have to be formally offered or admitted into evidence because the trial court had already considered them in ruling on the pretrial motion to quash the warrant.
2. The affidavit established sufficient probable cause to justify issuance of the warrant.
3. The evidence was sufficient to support the convictions because the dated lottery sheets found in Lee's possession on January 12 could reasonably be inferred to have been prepared and possessed on the dates appearing on the sheets.
4. The convictions were not clearly erroneous because the evidence was sufficient to support a reasonable inference of guilt.

Questions Presented

1. Whether the search warrant and supporting affidavit had to be formally introduced into evidence at trial.
2. Whether the facts stated in the affidavit established probable cause for issuance of the search warrant.
3. Whether the evidence was sufficient to support convictions for possession of lottery records on January 1 and January 8, 1951.
4. Whether the bench-trial convictions were clearly erroneous.

Disposition

affirmed