Taneja v. State, 149 A.3d 762

Preeta Gabba was shot three times and killed while walking to a bus stop in Germantown, MD on October 12, 2013; Baldeo Taneja (former husband) and Raminder Kaur (his wife) were tried together and convicted of first-degree premeditated murder, conspiracy, and handgun use.
The State’s case was circumstantial: the .357 Ruger LCR used in the killing was recovered from Taneja and Kaur’s car ~30 hours after the murder; Taneja had purchased the gun five weeks earlier; Taneja’s DNA was on both guns.
Motive/evidence: longstanding acrimony from contentious divorce and alimony disputes; Taneja had attended gun training and purchased two revolvers with Kaur present; GPS and hotel records tied them to the area the night before and briefly to the Amway conference the morning after.
Defense theory: lack of criminal agency by Taneja/Kaur and assertion that other persons (notably Kaur’s son Deepinder Singh) had motive and opportunity to kill Gabba.
At trial defense sought to call three subpoenaed witnesses (Deepinder Singh, Dan Wright, and Utsav Taneja) who were present but the court excluded them after detailed proffers; defense argued exclusion violated compulsory process/due process.
On appeal, the Court of Special Appeals reviewed whether exclusion of those witnesses was an abuse of discretion and concluded the trial court did not violate Taneja’s right to present a defense.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court violated defendant’s Sixth Amendment/Compulsory Process right by excluding three defense witnesses who were subpoenaed and present	Taneja: exclusion prevented presentation of alternative-suspect evidence (Singh) and thus gutted his defense; relied on Kelly to say proffer requirement and exclusion were improper	State/Kaur: proffered testimony was inadmissible (hearsay), not sufficiently relevant, speculative, and would mislead/confuse jury; trial court properly exercised discretion	Court: affirmed exclusion — no abuse of discretion; witnesses’ proffered evidence was tangential, speculative, and not sufficiently relevant to support an alternative-suspect defense; Kelly distinguishable

Washington v. Texas, 388 U.S. 14 (1967) (Compulsory Process Clause protects right to present witnesses and defense)
Taylor v. Illinois, 484 U.S. 400 (1988) (right to present witnesses is not absolute; inadmissible or unreliable evidence may be excluded)
Holmes v. South Carolina, 547 U.S. 319 (2006) (alternative-suspect evidence that only raises bare suspicion may be excluded)
Kelly v. State, 392 Md. 511 (2006) (trial court erred by requiring proffers and barring defense witnesses prematurely; compelled proffer can violate right to present defense)
Void v. State, 325 Md. 386 (1992) (trial court erred by quashing subpoenas without hearing witnesses; defendant must be allowed to examine subpoenaed witnesses to test admissibility)
Muhammad v. State, 177 Md. App. 188 (2007) (defendant’s right to present a defense is subject to Rules 5-401/5-403 relevance and balancing)