Robinson v. State
436 Md. 560
| Md. | 2014Background
- Emmanuel Ford Robinson was charged in Montgomery County with six counts related to a burglary scheme with Roland Spence.
- During trial, defense opening statements asserted no physical evidence would link Robinson to the crimes, emphasizing lack of fingerprints, DNA, and other forensic proof.
- The trial court gave an anti-CSI or 'no duty' instruction stating there is no legal requirement to use specific investigative techniques or tests, over defense objection.
- Defense cross-examined officers about testing and forensic procedures; the State did not present rebuttal testimony before instructions were given.
- Robinson was convicted of conspiracy to commit first degree burglary; other counts were resolved by acquittal or dismissal.
- The Maryland Court of Special Appeals affirmed; the Supreme Court granted certiorari to reconsider the anti-CSI instruction in light of Atkins and Stabb.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the anti-CSI instruction was abused | Robinson argued defense remarks triggered improper instruction and that the court should curtail such curative instruction. | State contends no abuse; instruction was a proper curative measure given defense insinuations about lack of forensic evidence. | Trial court erred in giving the instruction. |
| Whether the State's cross-examination of a plea-witness reading facts was improper | Robinson alleged the court improperly admitted facts from a co-defendant’s plea hearing without consent. | State contends evidence was properly read and admissible under cross-examination framework. | Not addressed on appeal; decision focused on issue 1. |
Key Cases Cited
- Atkins v. State, 421 Md. 434 (Md. 2011) (abuse for preemptive anti-CSI instruction when evidence pivotal)
- Stabb v. State, 423 Md. 454 (Md. 2011) (curative use only; no-duty instruction requires empirical support)
- Evans v. State, 174 Md.App. 549 (Md. App. 2007) (anti-CSI instruction reviewed for improper impact)
- Sample v. State, 314 Md. 202 (Md. 1988) (absence of evidence may support reasonable doubt)
- Tucker v. State, 407 Md. 368 (Md. 2009) (harmless error review; cross-racial instruction not harmless)