Decker v. State, 408 Md. 631

Summary

The Maryland Court of Appeals held that evidence that the defendant left the courthouse on a previously scheduled trial date was admissible as circumstantial evidence of consciousness of guilt. Applying the four-inference framework for evaluating consciousness-of-guilt evidence, the court concluded that the circumstances supported an inference that the departure constituted flight from prosecution and that the evidence was not unfairly prejudicial under Maryland Rule 5-403. The court affirmed the judgment of the Court of Special Appeals and did not reach the State's conditional cross-petition concerning preservation of a challenge to the flight instruction.

Holdings

1. The court did not need to address the State's cross-petition because Decker challenged only the admissibility of the courthouse-departure testimony and raised no issue concerning the flight instruction.
2. Evidence that Decker left the courtroom and courthouse immediately before the scheduled commencement of his trial was relevant circumstantial evidence of consciousness of guilt and was not inadmissible under Maryland Rule 5-403.

Questions Presented

1. Whether the trial court erred by admitting evidence that Decker left the courthouse on a previously scheduled trial date before trial commenced as evidence of consciousness of guilt.
2. Whether the Court of Special Appeals erred by failing to address the State's argument that Decker's challenge was not preserved because he did not object to the flight instruction.

Disposition

affirmed