STATE v. SAMPLE

No. 54, Sept. Term, 2019.

228 A.3d 171 (2020)

468 Md. 560

STATE of Maryland, v. Hayes SAMPLE.

Court of Appeals of Maryland.

May 11, 2020.


Attorney(s) appearing for the Case

Argued by Peter R. Naugle , Asst. Atty. Gen. ( Brian E. Frosh , Atty. Gen. of Maryland of Baltimore, MD) on brief, for Petitioner.

Argued by Rachel Marblestone Kamins , Asst. Public Defender ( Paul B. DeWolfe , Public Defender of Maryland of Baltimore, MD) on brief, for Respondent.

Argued before: Barbera, C.J.; McDonald, Watts, Hotten, Getty, Booth and Biran, JJ.


It is axiomatic that for a trial court to admit evidence, there must be sufficient indicia that the evidence is authentic—i.e., that the evidence "is what its proponent claims." Md. R. 5-901(a). A party can sufficiently authenticate evidence through "[c]ircumstantial evidence, such as appearance, contents, substance, internal...

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