O'SULLIVAN v. STATE

No. 3, Sept. Term, 2021.

265 A.3d 1015 (2021)

476 Md. 602

Michael O'SULLIVAN v. STATE of Maryland.

Court of Appeals of Maryland.

December 17, 2021.


Attorney(s) appearing for the Case

Argued by Kristin C. Tracy and Thomas M. Donnelly (Law Offices of Thomas M. Donnelly, LLC, Baltimore, MD), on brief, for Petitioner/Cross-Respondent.

Argued by Peter R. Naugle , Asst. Atty. Gen. ( Brian E. Frosh , Atty. Gen. of Maryland, Annapolis, MD), on brief, for Respondent/Cross-Petitioner.

Getty, C.J., McDonald, Watts, Hotten, Booth, Biran, Irma S. Raker (Senior Judge, Specially Assigned), JJ.


Under Maryland's common law, the State may not obtain a conviction for perjury based solely on the word of one witness who testifies at trial that the defendant gave false testimony in the underlying case. If the State introduces that kind of direct evidence through a witness, the State must either put on a second witness who also provides...

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