MUHAMMAD v. STATE

No. 826, September Term, 2014.

115 A.3d 742 (2015)

223 Md. App. 255

Kamal MUHAMMAD a/k/a Melvin Caldwell, v. STATE of Maryland.

Court of Special Appeals of Maryland.

May 29, 2015.


Attorney(s) appearing for the Case

Wyatt Feeler ( Paul B. DeWolfe , Public Defender, on the brief), Baltimore, MD, for appellant.

Benjamin A. Harris ( Brian E. Frosh , Atty. Gen., on the brief), Baltimore, MD, for appellee.

Panel: DEBORAH S. EYLER, ARTHUR, FRIEDMAN, JJ.


In this appeal we hold that the Circuit Court for Baltimore City erred by admitting into evidence, as a prompt complaint of sexual assault, a factually detailed prior consistent statement of a sexual assault victim; and that the error was not harmless beyond a reasonable doubt.

Melvin Caldwell, a/k/a Kamal Muhammad,...

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