Williams v. State, 416 Md. 670

Dana Drake was killed in Baltimore City around 3:00 a.m. on February 21, 1998, and Tony Williams was later indicted for first-degree murder, a handgun offense, and related charges.
Brenda O'Carroll, a key eyewitness, testified at Williams's 1999 trial about seeing Williams pursue and shoot Drake; Shannond Fair corroborated gunfire nearby but did not identify the shooter.
The State introduced additional impeachment and motive evidence at the 1999 trial, including a police informant, S. Williams, who testified Williams confessed to the murder while jailed with him.
The State failed to disclose before Williams's first trial that S. Williams was a paid informant; this Brady-like failure was later recognized in appellate proceedings.
Before Williams’s second trial (2007), Detective Massey disclosed for the first time that Brenda O'Carroll had described herself as legally blind; this information had not been provided to Williams in time for the first trial.
The circuit court allowed the State to play O'Carroll’s videotaped first-trial testimony in the second trial, while permitting some considerations about her vision after defense inquiry.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the admission of O'Carroll's videotaped testimony violate the Confrontation Clause?	Williams contends he lacked fair cross-examination due to late discovery of blind-descriptor.	State argues Williams had opportunity and motive to cross-examine at the first trial; former testimony falls within Rule 5-804(b)(1).	No federal Confrontation Clause violation; admissibility analyzed under Maryland evidentiary rules with remedy concerns.
Did the State's late disclosure of O'Carroll's vision statement constitute Brady or discovery violation requiring dismissal of the indictment?	Late disclosure prejudiced Williams by impairing cross-examination and trial strategy; warranting dismissal with prejudice.	Brady violation present but cured; dismissal not required; remedy at second trial was adequate under standards.	The discovery violation occurred; remedy was inadequate; reversal and remand warranted.
Was the remedy chosen by the circuit court (allowing redaction and related evidence) adequate to mitigate prejudice?	Remedy failed to restore fair cross-examination; the videotape should have been redacted or excluded.	Remedy provided impeachment avenues; the court acted within discretionary limits to balance prejudice and information access.	Remedy was an abuse of discretion; new trial with proper redaction or exclusion is required.

Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (prosecution must disclose favorable evidence irrespective of good/bad faith)
Strickler v. Greene, 527 U.S. 263 (U.S. 1999) (true Brady violation requires prejudice from suppression)
Ware v. State, 348 Md. 19 (Md. 1997) (impeachment evidence and witness credibility obligations under discovery rules)
Henry v. State, 324 Md. 204 (Md. 1991) (duty to disclose prior inconsistent statements by witnesses)
State v. Williams, 392 Md. 194 (Md. 2006) (Brady discovery extends to information in prosecutors' office and witness credibility considerations)
United States v. Salim, 855 F.2d 944 (2d Cir. 1988) (similar-motive and opportunity to develop former testimony informs admissibility)
Yearby v. State, 414 Md. 708 (Md. 2010) (Brady discovery obligations and timing considerations)