Preston v. State, 96 A.3d 800

Preston was convicted in Baltimore City Circuit Court of first-degree murder, handgun use in a crime of violence, and carrying a handgun.
Two eyewitnesses, Katrina Harrell and Nichelle Payton, testified; Payton’s cooperation was tied to protective housing provided by police.
Defense sought MJPI-Cr 3:13, the Witness Promised Benefit instruction, based on Payton’s housing arrangement.
The court declined the instruction during trial and again before final jury instructions, citing lack of proven quid pro quo.
Payton’s testimony was corroborated by Harrell; the court ultimately denied the instruction and convicted Preston.
The appellate court held the trial court did not abuse its discretion in denying the instruction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court abused discretion by declining the witness promised benefit instruction.	Preston argues Payton expected a housing benefit for cooperation.	State contends no promise or quid pro quo existed and standard credibility instructions sufficed.	No abuse of discretion; instruction properly denied.

Dickey v. State, 404 Md. 187 (Md. 2008) (rules for when 4-325(c) instruction is generated by evidence)
Gunning v. State, 347 Md. 332 (Md. 1997) (identification instruction left to trial court discretion; may be covered by other instructions)
Stouffer v. State, 118 Md. App. 590 (Md. App. 1997) (informant benefit instruction not required absent financial gain evidence)
Patterson v. State, 356 Md. 677 (Md. 1999) (missing evidence instruction not mandatory where other inferences exist)
Hoffa v. United States, 385 U.S. 293 (S. Ct. 1966) (informant credibility instruction not required; general credibility suffices)