Grimm v. State
135 A.3d 844
Md.2016Background
- In 2013 police obtained an anonymous letter alleging an inappropriate relationship between petitioner Angela Grimm and her stepson Quentin (who had moved in at 16 and was 19 at interview).
- Petitioner was interviewed, read Miranda rights, waived them, and gave a recorded extrajudicial confession admitting 5–10 instances of sexual intercourse with Quentin and uncertainty about the paternity of her young child.
- The State immunized Quentin and compelled him to testify; at trial he acknowledged residing with petitioner and Facebook contacts but repeatedly answered “I don’t remember” to whether sexual activity occurred.
- The State introduced petitioner’s recorded confession and Quentin’s live testimony (which denied recollection); no medical, physical, or other independent evidence of sexual abuse was produced.
- Petitioner was convicted on two counts of sexual abuse of a minor; the Court of Special Appeals affirmed. The Court of Appeals granted certiorari and reversed, holding the confession lacked required corroboration.
Issues
| Issue | State's Argument | Petitioner Grimm's Argument | Held |
|---|---|---|---|
| Whether a witness’s testimony that he “doesn’t remember” can corroborate a defendant’s extrajudicial confession | Quentin’s testimony corroborated elements (household member, age) and his implausible non-memory permitted an inference that the sexual acts occurred | An extrajudicial confession cannot support a conviction without independent evidence of the corpus delicti; Quentin’s “I don’t remember” testimony does not establish the essential harm (sexual abuse) | No. A witness’s failure to recall does not supply independent corroboration of the corpus delicti; conviction reversed |
| Whether an uncorroborated confession alone can sustain a conviction for sexual abuse of a minor | The confession, combined with limited testimony about living arrangements and age, was sufficient when viewed with permissible inferences | Confession alone is insufficient under Maryland’s corroboration rule | No. Maryland requires independent evidence corroborating the corpus delicti; confession alone insufficient |
| Whether disbelief of a non-party witness’s testimony permits an inference that the opposite is true (expansion of the “scienter” exception) | The scienter exception should permit drawing adverse inferences from inherently implausible testimony by a non-neutral non-party witness | The scienter exception is limited to party witnesses (defendants/co-defendants) denying scienter and cannot be expanded to non-party witnesses | The court rejected expansion; disbelief of a non-party’s testimony cannot be turned into affirmative proof of the opposite without independent evidence |
| What inferences a fact-finder may draw from disbelieving a witness | State urged the jury could infer the sexual acts occurred because Quentin’s denials were preposterous | Grimm argued jury may only discredit testimony and cannot infer the opposite without supporting evidence | Held that disbelieving testimony is not evidence of the opposite; only a narrow scienter exception (for party witnesses with additional proof) allows such inferences |
Key Cases Cited
- Bradbury v. State, 233 Md. 421 (confession must be corroborated by independent evidence of corpus delicti)
- Ballard v. State, 333 Md. 567 (corroboration may be small but must tend to prove the major/essential harm)
- Miller v. State, 380 Md. 1 (reaffirming that conviction cannot rest solely on uncorroborated confession)
- Hayette v. State, 199 Md. 140 (disbelief alone generally does not permit finding the contrary; scienter exception described)
- Larocca v. State, 164 Md. App. 460 (intermediate appellate discussion of implausible testimony and party/co-defendant contexts; distinguished)