Workman v. United States, 15 A.3d 264

Workman was convicted of first-degree murder while armed, possession of a firearm during a crime of violence, and two counts of carrying a pistol without a license for two incidents in 2006.
February 6, 2006: alleged murder of an acquaintance, forming the February counts including related weapon charges.
March 10, 2006: Workman arrested; alleged possession of a pistol on a car rear floorboard, charged as the March CPWL count with the March weapon allegedly being the February murder weapon.
Workman moved to sever the March CPWL count from the February counts, arguing prejudice because evidence would be inadmissible in a separate trial.
The trial court denied severance, finding mutual admissibility of evidence and lack of a sufficient proffer of prejudice.
During trial, the court proposed a motive-related instruction; Workman sought stronger language stating absence of motive supports innocence; the court declined and gave a balanced instruction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by denying severance	Workman contends prejudice from joinder would require severance.	Workman argues lack of proffer and potential cross-use of evidence prejudices one count over another.	No abuse; denial affirmed due to inadequate proffer and mutual admissibility.
Whether the motive instruction was properly given	Workman asserts absence of motive should be treated as exculpatory and favor his innocence.	Workman argues the instruction was not strong enough.	Instruction was proper and balanced; no reversible error.

Parker v. United States, 751 A.2d 943 (D.C.2000) (standard for severance abuse and prejudice)
Arnold v. United States, 511 A.2d 399 (D.C.1986) (discretionary severance decision framework)
Cox v. United States, 498 A.2d 231 (D.C.1985) (abuse of discretion standard for severance)
Bailey v. United States, 10 A.3d 637 (D.C.2010) (most compelling prejudice standard)
Roy v. United States, 652 A.2d 1098 (D.C.1995) (need for proffer to show prejudice in severance)
Shotikare v. United States, 779 A.2d 335 (D.C.2001) (mutual admissibility does not bar prejudice evidence)
Leasure v. United States, 458 A.2d 726 (D.C.1983) (mutual admissibility of evidence across counts)
Horton v. United States, 377 A.2d 390 (D.C.1977) (evidence admissible across joined offenses)
Cross v. United States, 118 U.S.App.D.C. 324 (1972) (joinder and testimony constraint under mutually admissible evidence)
Crutchfield v. United States, 779 A.2d 307 (D.C.2001) (mutual admissibility and severance considerations)
Byrd v. United States, 502 A.2d 451 (D.C.1985) (severance considerations when offenses joined)
In re Walker, 856 A.2d 579 (D.C.2004) (notice and opportunity to present factual/legal grounds on appeal)
Bright v. United States, 698 A.2d 450 (D.C.1997) (presence/absence of motive as factor in reasonable doubt instruction)
Tyree v. United States, 942 A.2d 629 (D.C.2008) (defense instruction balancing approach on motive)