Fields v. State
432 Md. 650
| Md. | 2013Background
- May 28, 2003: a drive-by shooting in Baltimore killed James Bowens and wounded William Courts; Fields and Colkley were charged, convicted, convictions later reversed and retried in 2010 and reconvicted.
- Before the 2010 retrial, defendants subpoenaed Baltimore Police Internal Investigations Division (IID) files showing an IID investigator found misconduct "sustained" against Detectives Massey and Snead (alleged falsified overtime/time sheets).
- The Police Department moved to quash; the trial court reviewed only summaries in camera and denied defense access to the IID files under Maryland Public Information Act (PIA) confidentiality and the court’s view of limited relevance.
- At trial the defense sought to cross-examine the detectives about the sustained IID findings under Md. Rule 5-608(b); the trial court barred inquiry, reasoning the defense lacked extrinsic proof and the discovery denial foreclosed the required factual basis.
- The Court of Appeals held the motion court erred by not following the Zaal balancing/procedure for confidential-record discovery and the trial court erred by denying the opportunity to establish a reasonable factual basis for impeachment; errors were not harmless and warranted a new trial.
Issues
| Issue | Petitioners' Argument | State's Argument | Held |
|---|---|---|---|
| Whether defense could obtain IID personnel files that are PIA-exempt | Need-to-inspect shown by proffer; files likely contain impeachment evidence relevant to detectives' credibility | PIA confidentiality and administrative closure mean files not discoverable; sustained finding is mere accusation not usable for impeachment | Reversed: court must apply Zaal procedure; in camera review of full files (or counsel access) required and denial was error |
| Whether defendants could cross-examine detectives about alleged prior misconduct under Md. Rule 5-608(b) after discovery denial | IID investigator sustained findings provide a reasonable factual basis to allow Rule 5-608(b) inquiry into untruthfulness | Defense cannot establish reasonable factual basis without files; mere allegations not admissible; extrinsic proof barred | Reversed: trial court erred by denying opportunity to establish reasonable factual basis; such cross-examination could be permitted |
| Whether the discovery and impeachment errors were harmless | Impeachment of detectives would bear on credibility of investigative evidence and witness statements; errors could have influenced jury | Detectives' testimony was peripheral compared to eyewitnesses; any error was harmless | Not harmless: Court cannot say beyond a reasonable doubt the errors did not affect verdict; remand for new trial |
| Proper procedure for reviewing confidential records sought for impeachment (Zaal test application) | Zaal requires reasonable-possibility showing and then in camera review with consideration of counsel participation; defense counsel should be allowed role given proffer | Court discretion to protect confidentiality; summaries may suffice | Court must adhere to Zaal: only deny access if file contains nothing "even arguably relevant and usable"; may allow counsel review under protective order |
Key Cases Cited
- Zaal v. State, 326 Md. 54 (1992) (sets test/procedure for obtaining confidential records — defendant must show need; court may review in camera or allow counsel access)
- Robinson v. State, 354 Md. 287 (1999) (confidentiality of internal investigations yields to defendant's confrontation/due process rights in appropriate cases)
- Cox v. State, 298 Md. 173 (1983) (prior bad-act impeachment rules; mere accusations generally inadmissible; trial judge must ensure reasonable basis)
- Dorsey v. State, 276 Md. 638 (1976) (harmless-error standard — reversal required unless error shown beyond a reasonable doubt to have not influenced verdict)
- Montgomery Cnty. v. Shropshire, 420 Md. 362 (2011) (internal affairs records are personnel records and generally PIA-exempt)
- Davis v. Alaska, 415 U.S. 308 (1974) (defendant’s right of confrontation may outweigh state confidentiality interests where impeachment is implicated)