Joiner v. State

CourtCourt of Special Appeals of Maryland
DecidedMay 30, 2025
Docket1949/23
StatusPublished

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

Bluebook
Joiner v. State, (Md. Ct. App. 2025).

Opinion

Michael D. Joiner v. State of Maryland, No. 1949, Sept. Term, 2023. Opinion filed on May 30, 2025, by Wells, C.J.

CRIMINAL LAW – DEFENSE – HABITATION

Under Maryland case law, the trial court must give a specific instruction to the jury when three conditions are met: (1) the instruction is a correct statement of the law, (2) the instruction is applicable under the facts of the case, and (3) the contents of the instruction were not fairly covered elsewhere in jury instructions actually given. The defense of habitation applies when a defendant has used deadly force in response to a reasonable belief that the victim intended to commit a felony in the home or to inflict serious bodily harm or death on the inhabitants of the home. The only difference between defense of the home and defense of the person is defense of the home does not require a duty to retreat.

The trial court in this case was not required to give the defense of habitation instruction because it was not applicable to the facts of this case. There was no evidence from which a jury could conclude either victim, Ted Rill or Lester Rill, entered or attempted to enter Joiner’s home. Additionally, the trial court was not required to give the instruction because its contents were fairly covered in the trial court’s self-defense instruction that advised the jury Joiner had no duty to retreat if he was in his home or upon the curtilage of his home.

CRIMINAL LAW – TESTIMONY – OPENED DOOR DOCTRINE

The opened door doctrine permits a party to introduce evidence that might not be admissible in order to respond to certain evidence put forth by opposing counsel. The doctrine is applicable where the cross-examination of a witness has expanded the scope of the witness’s testimony on direct.

In this case, Joiner first elicited Corporal Theodore Buck’s opinion of the identity of the aggressor at the early stages of the investigation. In doing so, Joiner opened the door for the State, on redirect, to rebut the significance of that evidence by asking Corporal Buck whether his opinion as to the identity of the aggressor changed during the course of the investigation. Accordingly, the trial court did not err in permitting the State to elicit Corporal Buck’s testimony.

CRIMINAL LAW – IMPEACHMENT – PRIOR CONDUCT

Maryland Rule 5-608(b) permits the impeachment of a witness based on their own prior conduct that did not result in a conviction but that the court finds probative of a character trait of untruthfulness. Acts of misconduct are only relevant if they logically relate to a witness’s character for untruthfulness. Additionally, when impeachment is the aim, the relevant inquiry is not whether the witness has been accused of misconduct by some other person, but whether the witness actually committed the prior bad act. To overcome an objection, the proponent must demonstrate a reasonable factual basis for asserting the conduct occurred.

In this case, the court properly sustained the State’s objection when Joiner attempted to cross-examine Ted Rill about a police report containing accusations that Rill pointed a gun at someone. Joiner’s examination was not logically related to Rill’s character for untruthfulness, and it was a hearsay accusation of Rill’s guilt.

CRIMINAL LAW – DEFENSE – SUFFICIENCY OF EVIDENCE

To be entitled to a jury instruction with respect to self-defense or defense of others, the defendant has the burden of initially producing some evidence on the issue of mitigation or self-defense sufficient to give rise to a jury issue. Once the issue has been generated by the evidence, the State must prove beyond a reasonable doubt that the defendant did not act in self-defense. To defeat a motion for judgment of acquittal where a claim of self- defense or defense of others has been raised, it is not necessary for the State to affirmatively negate any evidence tending to support such a claim. It is up to the jury to decide whether evidence that the defendant acted in self-defense or in defense of others is worthy of belief.

While Joiner’s testimony in this case may have generated the issue of self-defense and defense of others for the jury’s consideration, that evidence did not establish he was entitled to judgment in his favor as a matter of law. The jury was free to disbelieve Joiner’s testimony that Ted Rill threatened to kill him and his family, and Rill initiated the confrontation. Alternatively, the jury could have reasonably concluded the degree of force used by Joiner was unreasonable. Accordingly, the court did not err in denying Joiner’s motion for judgment of acquittal. Circuit Court for Carroll County Case No. C-06-CR-23-000119

REPORTED

IN THE APPELLATE COURT

OF MARYLAND

No. 1949

September Term, 2023

______________________________________

MICHAEL D. JOINER

v.

STATE OF MARYLAND ______________________________________

Wells, C.J., Albright, Eyler, Deborah S. (Senior Judge, Specially Assigned),

JJ. ______________________________________

Opinion by Wells, C.J. ______________________________________

Filed: May 30, 2025

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

2025.05.30 14:56:17 -04'00' Gregory Hilton, Clerk A jury sitting in the Circuit Court for Carroll County convicted appellant Michael

D. Joiner of two counts of first-degree assault, two counts of use of a firearm in the

commission of a crime of violence, and two counts of reckless endangerment. The court

sentenced Joiner to a total of 32 years and two days of incarceration, with ten years of that

sentence suspended, and five years of supervised probation upon release. Joiner timely

appealed and presents four questions for our review:

1. Did the circuit court err in failing to propound the defense of habitation jury instruction?

2. Did the circuit court err in permitting the State to elicit an opinion from a witness that invaded the province of the jury?

3. Did the circuit court err in restricting the defense’s cross-examination of the alleged victim?

4. Is the evidence insufficient to sustain the convictions?

For the reasons that follow, we affirm the judgments of the circuit court.

FACTUAL AND PROCEDURAL BACKGROUND

We shall give a detailed recitation of the facts because of the issues presented in this

appeal. The State charged Joiner with shooting Ted Rill and pointing a gun at Lester Rill,

Ted’s father.1 The shooting and events that preceded it were captured on soundless video

from a home security surveillance camera that was trained on Joiner’s backyard and the

backyard of the adjoining property. The defense theory of the case was Joiner acted in self-

1 Several of the individuals who testified and/or were discussed in the testimony of others share the same surname, Rill. For clarity and ease of reading, we refer to each by their first name. We intend no disrespect in doing so. defense and defense of others.2

A. Evidence Adduced by the State

Ted and Lester work for Rill’s Construction company, which is owned by Rusty

Rill, Lester’s cousin. On January 30, 2023, a gasoline powered tamper, a piece of

construction equipment used to compact soil, was stolen from a company truck.

On February 10, 2023, Joiner called Ted’s mother, Vicki Parrish. Joiner told Parrish

he had the tamper and it was stolen by Geen Barnhouse and Justin Heiser, both of whom

were previously employed by Rill’s Construction. Joiner gave Parrish his address and said

the tamper could be picked up around noon that day.

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Bluebook (online)
Joiner v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joiner-v-state-mdctspecapp-2025.