Young v. State
174 A.3d 481
Md. Ct. Spec. App.2017Background
- Police executed a search warrant at 2580 Marbourne Ave., Baltimore, on May 28, 2014; officers detained Steven Young (found nearby), searched the house, and recovered heroin, oxycodone, methadone, alprazolam, and cash. Young made post‑arrest inculpatory statements and led officers to drugs in his bedroom.
- Young was indicted and convicted of possession and possession with intent to distribute multiple controlled dangerous substances; sentence was concurrent terms based on four intent‑to‑distribute counts.
- Pretrial, Young filed motions including a Franks motion and a suppression motion alleging unlawful seizure/arrest; he also asserted he and his wife had valid prescriptions for some seized drugs.
- At trial the State moved in limine to exclude written prescriptions as hearsay; the trial judge granted the motion without allowing Young to respond and without an offer of proof; Young did not explicitly object on the record.
- The court agreed to hear the suppression motion the next morning but did not; trial proceeded, Detective Larbi testified about the arrest and Young’s statements, and Young’s counsel made no contemporaneous objection.
- On appeal the Court of Special Appeals held the trial court erred in excluding the prescription evidence (it was not hearsay when offered as a statutory defense) but held Young waived review of the failure to hold a suppression hearing because counsel never pressed the matter or objected when the evidence was introduced.
Issues
| Issue | Plaintiff's Argument (Young) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether written prescriptions offered by Young were hearsay and admissible | Prescriptions were offered not for the truth of any medical assertions but as statutory defenses (Crim. Law §§ 5‑601, 5‑602) to show lawful possession; alternatively, statements fall under medical‑treatment hearsay exception; authentication burden minimal and Young had no chance to authenticate at trial | Prescriptions are hearsay if offered to prove that Young/ his wife had a medical need; not authenticated or certified; no proffer or witness to authenticate | Reversed: prescriptions not hearsay when offered to show existence of prescriptions as a legal defense and, if authenticated, admissible; trial court erred in excluding them |
| Whether trial court’s failure to hold/signal a ruling on suppression motion (and admission of Young’s post‑arrest statements) requires reversal | Young argued the court agreed to but then failed to hold the suppression hearing; his written motion preserved the issue and the court’s failure deprived him of a ruling | State argued Young waived the issue by not objecting when evidence was admitted and by failing to pursue the hearing at trial; no contemporaneous objection preserved the claim | Affirmed in part: suppression issue not preserved—Young waived review by not reminding the court or making contemporaneous objections; convictions based on heroin counts affirmed; convictions related to drugs tied to prescriptions reversed and remanded for new trial |
Key Cases Cited
- Bryant v. State, 361 Md. 420 (court excluded a toxicology report as hearsay/business‑record authentication issue)
- U.S. v. Bruner, 657 F.2d 1278 (D.C. Cir.) (prescriptions admitted not for truth of medical need but to show use to obtain drugs)
- Franks v. Delaware, 438 U.S. 154 (Supreme Court) (threshold showing required to obtain a Franks hearing)
- McDonald v. State, 347 Md. 452 (explaining Franks procedural/threshold requirements)
- Bernadyn v. State, 390 Md. 1 (hearsay is a legal question reviewed de novo)
- Malarkey v. State, 188 Md. App. 126 (failure to obtain or press for a ruling on a pending motion and failure to make a contemporaneous objection waives appellate review)