Abruquah v. State

240 A.3d 1205, 471 Md. 249
CourtCourt of Appeals of Maryland
DecidedOctober 27, 2020
Docket34pc/20
StatusPublished
Cited by5 cases

This text of 240 A.3d 1205 (Abruquah v. State) is published on Counsel Stack Legal Research, covering Court of Appeals of Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Abruquah v. State, 240 A.3d 1205, 471 Md. 249 (Md. 2020).

Opinion

Circuit Court for Prince George’s County Case No. CT12-1375X

IN THE COURT OF APPEALS

OF MARYLAND

No. 34

September Term, 2020

KOBINA EBO ABRUQUAH

v.

STATE OF MARYLAND

Barbera, C.J., McDonald Watts Hotten Getty Booth Biran,

JJ.

Pursuant to Maryland Uniform Electronic Legal Materials Act PER CURIAM ORDER (§§ 10-1601 et seq. of the State Government Article) this document is authentic.

2020-10-27 13:35-04:00 Watts and Hotten, JJ., dissent.

Suzanne C. Johnson, Clerk Filed: October 27, 2020 KOBINA EBO ABRUQUAH * IN THE

* COURT OF APPEALS

* OF MARYLAND v. * COA-REG-0034-2020

* No. 34

STATE OF MARYLAND * September Term, 2020

PER CURIAM ORDER

The Court having considered and granted the petition for a writ of certiorari in the

above-captioned case, it is this 27th day of October, 2020,

ORDERED, by the Court of Appeals of Maryland, that the judgment of the Court

of Special Appeals is vacated and the case is remanded to that Court with direction to

remand the case to the Circuit Court for Prince George’s County, pursuant to Maryland

Rule 8-604(d)(1) without affirming or reversing the judgment of the Circuit Court, in order

for the Circuit Court to consider whether, in light of this Court’s decision in Rochkind v.

Stevenson, No. 47 (September Term, 2019), the Circuit Court would reach a different

conclusion concerning the admission of firearm and toolmark identification testimony

based on the extensive hearing already conducted by the Circuit Court and such further

proceedings, if any, that the Circuit Court deems necessary. Costs to be paid by Petitioner.

/s/ Mary Ellen Barbera Chief Judge Circuit Court for Prince George’s County Case No. CT12-1375X IN THE COURT OF APPEALS

September Term, 2020 ______________________________________

STATE OF MARYLAND ______________________________________

Barbera, C.J. McDonald Watts Hotten Getty Booth Biran,

JJ. ______________________________________

Dissenting Opinion by Watts, J., which Hotten, J., joins. ______________________________________

Filed: October 27, 2020 Respectfully, I dissent from the Majority’s decision to grant the petition for a writ

of certiorari, vacate the Court of Special Appeals’s judgment, and remand (“GVR”) for

reconsideration in light of Stanley Rochkind v. Starlena Stevenson, ___ Md. ___, ___ A.3d

___, No. 47, Sept. Term, 2019, 2020 WL 5085877, at *2 (Md. Aug. 28, 2020),

reconsideration denied (Sept. 25, 2020). In short, the GVR that the Majority orders is a

waste of judicial resources because the circuit court has already conducted an extensive

hearing over the course of six days on a motion in limine to exclude firearm or toolmark

identification testimony filed by Petitioner, and the issue concerning the application of

Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 579 (1993), is not preserved for appellate

review. In this case, Petitioner’s line of attack on the State’s expert opinion was based on

the contention that the method that the expert used to tie him to the murder—firearms

toolmark examination—was no longer generally accepted, i.e., failed to pass muster under

the Frye-Reed1 standard, and Petitioner questioned the reliability of the expert’s

methodology. As the Court of Specials noted, the Circuit Court for Prince George’s

County “declin[ed] to hold a Frye-Reed hearing[,]” Kobina Ebo Abruquah v. State, No.

2176, Sept. Term, 2018, 2020 WL 261722, at *6 (Md. Ct. Spec. App. Jan. 17, 2020), but

nonetheless conducted an extensive evidentiary hearing, see id. at *1-2. During the

hearing, the circuit court heard testimony from expert witnesses for Petitioner and the State

and admitted documents concerning firearms examination into evidence. Following the

hearing, the circuit court issued a written opinion and order denying Petitioner’s motion in

1 See Frye v. United States, 293 F. 1013 (D.C. Cir. 1923); Reed v. State, 283 Md. 374, 391 A.2d 364 (1978). part and granting it in part. In the opinion, the circuit court determined that toolmark

examination remains generally accepted and reliable “under the Frye-Reed standard” and

ruled that the expert could give an opinion as to whether bullets recovered from the victim

could be attributed to a gun recovered from Petitioner, but could not state the opinion in

terms of “absolute or scientific certainty[.]”2

In sum, both the circuit court and the Court of Special Appeals determined that the

expert’s testimony was admissible despite Petitioner’s arguments otherwise. As a result of

this Court’s GVR, the circuit court, and potentially the Court of Special Appeals, will need

to spend time and effort determining whether in light of this Court’s decision in Rochkind

it “would reach a different conclusion concerning the admission of firearm and toolmark

identification testimony” and assessing entirely different grounds for possibly excluding

the expert’s testimony than those advanced initially in the circuit court, and ones that

Petitioner never raised as a challenge—namely, whether firearms toolmark examination in

general, or the expert’s testimony about it in particular, satisfies Daubert. The question in

this case that both the circuit court and the Court of Special Appeals addressed is whether

toolmark examination is generally accepted in the relevant scientific community and

whether the methodology used by the expert was reliable. It appears that nothing in the

record in this case indicates that there would be any further basis for a Daubert challenge

to the expert’s testimony or to firearms toolmark examination. The GVR in this case would

2 In the circuit court, Petitioner was convicted of first-degree murder and use of a handgun in the commission of a crime of violence and sentenced to life imprisonment plus twenty years.

-2- require the circuit court, and/or the Court of Special Appeals, to readdress matters that have

already been decided and to entertain a Daubert challenge that Petitioner never made, and

that the record does not appear to give a basis for.

Any issue as to whether the circuit court was required to conduct a Daubert hearing,

and/or engage in a Daubert analysis, is not preserved for appellate review because it was

neither “raised in [n]or decided by the [circuit] court[,]”3 Md. R. 8-131(a), and none of the

three questions that Petitioner presented in the petition for a writ of certiorari pertain to

Daubert. Instead, in a footnote in the petition for a writ of certiorari, Petitioner stated that,

if this Court replaced the Frye-Reed standard with the Daubert standard in Rochkind, here,

“it could evaluate the reliability of the methodology using Daubert.” (Citing Savage v.

State, 455 Md. 138, 175 n.1, 166 A.3d 183, 204 n.1 (2017) (Adkins, J., concurring)).

In Rochkind, 2020 WL 5085877, at *18, this Court reasoned that its holding would

apply to “any other cases that [were] pending on direct appeal when [the] opinion [was]

filed, where the relevant question ha[d] been preserved for appellate review.” (Cleaned

up). This Court also stated: “In this context, the ‘relevant question’ is whether a trial court

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Cite This Page — Counsel Stack

Bluebook (online)
240 A.3d 1205, 471 Md. 249, Counsel Stack Legal Research, https://law.counselstack.com/opinion/abruquah-v-state-md-2020.