Hannah v. State, 23 A.3d 192

Hannah was convicted in Harford County of attempted murder of his former girlfriend's new boyfriend for an April 15, 2007 shooting.
During trial, the State cross-examined Hannah about ten rap lyrics and a drawing he allegedly authored two years earlier relating to guns and violence.
Hannah testified he had no possession or knowledge of guns and that the rap lyrics were not autobiographical admissions of crime.
The defense objected to the cross-examination as overly prejudicial and irrelevant, but the court overruled, admitting the lyrics and drawings for cross-examination.
The Court of Special Appeals affirmed; certiorari was granted to review whether the lyrics were admissible and whether a witness’s motive to testify could be excluded.
The Court held the cross-examination about the ten rap lyrics was prejudicial and not harmless error, reversing and remanding for a new trial; it also directed how evidence of a witness’s motive to testify falsely should be handled at retrial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether rap lyrics and drawings were admissible evidence	Hannah argues the lyrics are irrelevant and prejudicial, not probative of any issue and should have been excluded.	State contends lyrics and drawings rebut defense and show knowledge, intent, or credibility; proper balancing favors admissibility.	Admission of the ten lyrics was error and not harmless; reversed for a new trial.
Whether the State could exclude evidence of a key witness's motive to testify falsely	Hannah contends evidence of witness motive should be admissible under proper standards to challenge credibility.	State argues Calloway v. State and Martinez v. State standards govern admissibility of motive evidence and may limit it.	The retrial must apply Calloway and Martinez standards for witness-motive evidence.

Marshall v. State, 346 Md. 186 (Md. 1997) (cross-examination limits; prejudice rule)
King v. State, 407 Md. 682 (Md. 2009) (prejudice and evidentiary rules for cross-examination)
State v. Askew, 245 Conn. 351 (Conn. 1998) (prejudicial impact versus probative value)
Cheeseboro v. State, 552 S.E.2d 300 (S.C. 2001) (rap lyrics admitted; caution on prejudicial impact)
Foster (United States v. Foster), 939 F.2d 445 (7th Cir. 1991) (limited purpose admission of rap verse for knowledge/intent)
Giese (United States v. Giese), 597 F.2d 1170 (9th Cir. 1979) (door-opening principle for cross-examination about writings)