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trialtestimonyrelevanceadmissibility
appealtrialtestimonypatentappellant

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Dorsey v. State, 276 Md. 638, 350 A.2d 665

Facts

Donald Dorsey was convicted of robbery, assault, and using a handgun during a violent crime after a robbery at a carry-out shop in Baltimore. The victim, Mrs. Doris Fuller, was confronted by three men, one armed with a gun, who demanded money and threatened her life. Although she initially misidentified Dorsey's brother as one of the robbers, she later identified Dorsey as the perpetrator after he returned the stolen gun to her.

At about 11:30 P.M. on December 27, 1972, Mrs. Doris Fuller, the proprietress of the ‘Red Bull’ carry-out shop, at 2301 East North Avenue, in Baltimore, was confronted by three young men, one of whom was armed with a gun, and was told ‘This is a stickup.’ Several patrons were directed to lie on the floor; she was ordered ‘not to move.’ One of the robbers searched her pockets and relieved her of a .22 caliber pistol; another of the group, whom she identified at the trial as the appellant, ordered her to open the cash register and he removed its contents. She testified that as the bandits left the premises, the appellant had directed one of his confederates to ‘Fire on her, man, fire on her.’ She however was not further harmed.

Issue

Did the trial court err in allowing Detective Richard Simmons to answer a question regarding the percentage of his arrests that resulted in convictions, and if so, was the error prejudicial?

Did the trial court err in allowing Detective Richard Simmons to answer a question regarding the percentage of his arrests that resulted in convictions, and if so, was the error prejudicial?

Rule

The admissibility of evidence in a criminal case is determined by its relevance to the issues at hand, and evidence that is irrelevant or extraneous to the main issue should be excluded.

The principal issue in the appellant's trial was whether he was one of the perpetrators of the robbery. Detective Simmons' testimony, attempting to establish that a large percentage of those arrested by him for robbery were ultimately proven guilty, undertook to collaterally establish the detective's investigative successes, but had no probative value in tending to establish the proposition in issue-the identity of the appellant as one of the robbers-and was thus patently irrelevant.

Analysis

The court found that Detective Simmons' testimony about his arrest-conviction record was irrelevant to the issue of Dorsey's guilt. The testimony did not help establish whether Dorsey was one of the robbers and instead could mislead the jury by suggesting a higher likelihood of guilt based on the detective's past success rates. The court concluded that the erroneous admission of this evidence could have influenced the jury's decision.

The court found that Detective Simmons' testimony about his arrest-conviction record was irrelevant to the issue of Dorsey's guilt. The testimony did not help establish whether Dorsey was one of the robbers and instead could mislead the jury by suggesting a higher likelihood of guilt based on the detective's past success rates. The court concluded that the erroneous admission of this evidence could have influenced the jury's decision.

Conclusion

The court reversed Dorsey's conviction and remanded the case for a new trial, determining that the error in admitting the detective's testimony was prejudicial.

We conclude, as did the Court of Special Appeals, that the collateral evidence elicited from Detective Simmons, concerning his arrest-conviction record, was irrelevant and extraneous to the issue of the appellant's guilt or innocence, and that the trial court's ruling, permitting it, was manifestly erroneous.

Who won?

Donald Dorsey prevailed in the case because the court found that the trial court's error in admitting irrelevant evidence was prejudicial to his defense.

Donald Dorsey prevailed in the case because the court found that the trial court's error in admitting irrelevant evidence was prejudicial to his defense.

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