Ingram v. State, 427 Md. 717

On 16 July 2009, Ingram was indicted in Montgomery County for manslaughter by motor vehicle, reckless driving, failure to remain at the scene, and engaging in a race or speed contest from a 2008 incident.
Trial occurred 26–30 April 2010; the court limited defense closing by prohibiting discussion of certain comparative standards of proof but allowed discussion of preponderance, clear and convincing, and beyond a reasonable doubt.
The jury convicted Ingram of reckless driving and failure to remain at the scene of an accident resulting in bodily injury, but acquitted on manslaughter, racing, and death-scene charges; he received a five-year sentence with most suspended and five years’ probation plus a $500 fine.
Defense presented a seven-standard board; the State sought to limit it to two standards; Drake v. State was a central authority in the dispute.
Ingram appealed to the Court of Special Appeals, which affirmed; the Maryland Court of Appeals granted certiorari to review the trial court’s closing-argument discretion.
The Court held that the trial court’s restriction of extraneous standards was not an abuse of discretion and, even assuming abuse, the error was harmless given the defense’s broad latitude in closing argument and the strength of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the trial court's closing-argument restriction an abuse of discretion?	Ingram argues the court unduly restricted argument and hindered explaining proof standards.	State contends discretion to control closing argument to avoid confusion was proper.	No abuse; discretionary control upheld.
If abuse occurred, was any error harmless beyond a reasonable doubt?	The broader context and defense’s arguments justified testing all standards for juror understanding.	Any error would be harmless given substantial latitude and strong evidence of guilt.	Harmless error; affirmed.

Drake v. State, 186 Md.App. 570 (Md.App. 2009) (limits closing-argument discussion to avoid jury confusion)
Grillot v. State, 353 Ark. 294 (Ark. 2003) (upholds exclusion of extraneous standards to prevent confusion)
Wilhelm v. State, 272 Md. 404 (Md. 1974) (deference to trial court, limits on scope of closing argument)
Degren v. State, 352 Md. 400 (Md. 1999) (wide latitude in closing argument to invite reasonable inferences)
Mitchell v. State, 408 Md. 368 (Md. 2009) (trial court’s discretion in closing arguments; related to argument rebuttal)
Ruffin v. State, 394 Md. 355 (Md. 2006) (pattern jury instruction to avoid confusion in reasonable doubt)
White v. State, 66 Md. App. 100 (Md. App. 1986) (jurors’ understanding and trial court’s control of argument)
Savoy v. State, 420 Md. 232 (Md. 2011) (dissent cited on probability spectrum in reasonable doubt context)
Smith v. State, 388 Md. 468 (Md. 2005) (limited cross-racial identification discussion; contextual relevance)