Stringfellow v. State
199 Md. App. 141
Md. Ct. Spec. App.2011Background
- Stringfellow was convicted of possessing a regulated firearm after a disqualifying conviction and wearing, carrying, or transporting a handgun.
- Baltimore City detectives observed appellant with a handgun on Beaufort Street and saw him attempt to pass the gun to another person as they approached.
- A handgun with seven live rounds was recovered from the sidewalk; one witness contemporaneously described the handoff with appellant.
- Defense witness McKay testified that another man with him dropped the gun during a confrontation with two younger men, while police arrested appellant.
- Appellant challenged the voir dire question about requiring scientific evidence to convict, and challenged the sufficiency of the evidence to prove possession.
- The panel was reversed on both the voir dire issue and the sufficiency issue, and the case was remanded for a new trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Voir dire question improper | Stringfellow argues the CSI-like voir dire improperly pressured jurors toward conviction. | Stringfellow asserts the question signaled an improper foregone conclusion. | Convictions reversed for voir dire abuse; new trial ordered. |
| Sufficiency of possession evidence | State contends testimony about appellant holding the gun supports possession. | Stringfellow argues insufficient link to possession due to multiple people nearby, no flight, no fingerprints. | Evidence was sufficient; however, since voir dire error requires reversal, retrial ordered. |
Key Cases Cited
- Charles and Drake v. State, 414 Md. 726 (Md. 2010) (CSI effect voir dire question deemed improper language; preordains verdict)
- Hutchinson v. State, 287 Md. 198 (Md. 1980) (instructional error analysis framework for verdict directions)
- Corens v. State, 185 Md. 561 (Md. 1946) (death-penalty context; distinguishable from general voir dire)
- White v. State, 374 Md. 232 (Md. 2003) (purpose of voir dire to ensure impartial jury)
- Moore v. State, 412 Md. 635 (Md. 2010) (voir dire may explore attitudes that affect impartiality)
- North v. North, 102 Md.App. 1 (Md. 1994) (abuse of discretion standard in voir dire rulings)