Morris v. State
13 A.3d 1206
Md.2011Background
- Franklin Morris and Stewart Williams were jointly tried for armed robbery-related offenses in Baltimore City after a confrontation at The Wine Underground.
- A so-called miscellaneous agreement allowed Williams to proceed to a jury trial while effectively capping Williams’s sentence in exchange for certain concessions, and Morris remained in the joint trial.
- Williams waived opening/closing statements, the right to testify, and other trial rights, effectively making the joint trial non-bona fide.
- Williams’s pre-trial statements were introduced against him and, under Bruton/Marsh, could implicate Morris despite a limiting instruction.
- The trial court admitted Williams’s statements and Morris objected; the jury convicted Morris on multiple counts, and Williams was acquitted on at least one count.
- The Court of Special Appeals affirmed; this Court reversed, holding the miscellaneous agreement violated Morris’s confrontation rights and that the error was not harmless beyond a reasonable doubt.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Morris's Crawford/confrontation claim preserved and ripe for review? | Morris preserved confrontation concerns tangentially in trial and raised severance/Crawford issues on appeal. | State contends preservation was lacking and Williams, not Morris, was the proper complainant. | Morris preserved, at least in part; Crawford issue cognizable on appeal. |
| Did the miscellaneous agreement render the Williams–Morris trial non-bona fide and violate Crawford/Bruton? | Joint trial was a sham, enabling Crawford violation by admitting co-defendant's statement against Morris. | Joint trial was bona fide or akin to a sentencing cap; Crawford does not apply because the statement targeted Williams, not Morris. | The joint trial was not bona fide; Crawford issue applicable and reversible. |
| Was Williams's taped statement admissible against Morris under Bruton/Marsh and related limits? | Redactions/limits failed to cure Bruton-type prejudice to Morris because Williams’s statements implicated Morris indirectly. | Statement only implicated Williams; proper redaction and limiting instruction safeguarded Morris. | Bruton concerns valid; redaction insufficient; Crawford concerns separate. |
| Was the Crawford error harmless beyond a reasonable doubt? | Error substantially affected Morris's theory of defense given the unconventional joint trial. | Error could be harmless due to Morris’s own testimony and other corroborating evidence. | Not harmless beyond a reasonable doubt; reversal required. |
| What about the trial court’s handling of hearsay and the requested limiting instruction? | Evidentiary handling and lack of limiting instruction prejudiced Morris. | Hearsay issues were properly managed and limiting instructions were not requested as error. | Hearsay handling acceptable; limiting-instruction issue deemed non-prejudicial on remand guidance. |
Key Cases Cited
- Crawford v. Washington, 541 U.S. 36 (2004) (establishes confrontation-right limits for testimonial statements)
- Bruton v. United States, 391 U.S. 123 (1968) (prohibits use of co-defendant's out-of-court statement against another defendant)
- Richardson v. Marsh, 481 U.S. 200 (1987) (redaction approaches in joint trials; evidence admissibility when linked later)
- Smith v. State, 375 Md. 365 (2003) (recognizes plea-like bargain effects and sentencing cap considerations)
- Ogonowski v. State, 87 Md. App. 173 (1991) (sentencing-cap-like agreements and their enforceability)