Beaman v. State, 162 A.3d 864

In 1990, James P. Beaman was convicted by a jury of four counts of first-degree murder and related offenses; he received four consecutive life-without-parole terms. Multiple post-conviction petitions followed.
The crimes occurred at a fourth-floor apartment where four men were shot; one victim (Edmond Stephenson) apparently jumped out a bedroom window and left blood on the ground-level patio beneath the window.
Eyewitness Doria Rogers identified two men running from the scene; she later gave inconsistent testimony about which of the two was in front. Rogers identified Beaman and co-defendant Ervin Holton from photographic arrays.
Beaman filed a pro se petition (2012) under Md. Code, Crim. Proc. § 8-201 seeking post-conviction DNA testing of blood recovered from the patio, arguing that if the blood belonged to the victim it would show Rogers misidentified him (the dark-skinned runner) and thus be exculpatory.
The Circuit Court denied the petition, stating DNA testing would not "prove" Beaman's innocence and there was not a "substantial possibility" testing would have changed the verdict. Beaman appealed directly to the Court of Appeals.
The Court of Appeals reviewed de novo, held the trial court applied the wrong legal standard (requiring proof the testing would change the verdict), but affirmed denial on the merits because testing the patio blood had no reasonable probability of producing evidence tending to exculpate Beaman.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proper legal standard under Crim. Proc. § 8-201(d) for ordering post-conviction DNA testing	Beaman: court should apply the § 8-201(d) standard — whether a "reasonable probability" exists that testing has the scientific potential to produce exculpatory or mitigating evidence.	State: did not contest the standard but argued testing would not produce exculpatory evidence relevant to wrongful conviction.	Court: Trial court applied a stricter standard (requiring proof testing would change outcome); that was error as to legal standard.
Whether DNA testing of patio blood has the scientific potential to produce exculpatory evidence	Beaman: If testing shows the blood is the victim’s, it would demonstrate Rogers saw the victim (not Beaman) running and thus support misidentification.	State: Blood on the patio was consistent with the State’s account that the victim jumped from the window and bled there; the State never argued the blood was from a perpetrator. Testing would not tend to establish Beaman’s innocence.	Court: No reasonable probability testing would produce exculpatory evidence; victim’s blood on patio does not logically show Rogers misidentified Beaman. Petition denial affirmed.

Simms v. State, 409 Md. 722 (discussion of § 8-201 entitlement to DNA testing)
Blake v. State, 395 Md. 213 (purpose of § 8-201 to facilitate claims of actual innocence)
Thompson v. State, 395 Md. 240 (statutory purpose to aid exoneration)
Fuster v. State, 437 Md. 653 (review of trial court legal standard is de novo)
Gregg v. State, 409 Md. 698 (remand for testing when petition satisfies § 8-201)
Jackson v. State, 448 Md. 387 (no remand where petition is obviously futile)