Mason v. State

316 A.3d 529, 487 Md. 216
CourtCourt of Appeals of Maryland
DecidedMay 30, 2024
Docket21/23
StatusPublished
Cited by1 cases

This text of 316 A.3d 529 (Mason 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
Mason v. State, 316 A.3d 529, 487 Md. 216 (Md. 2024).

Opinion

Troy Mason v. State of Maryland, No. 21, September Term, 2023. Opinion by Hotten, J.

DISCOVERY – SANCTION FOLLOWING VIOLATION OF THE RULES – EXERCISE OF DISCRETION BY THE CIRCUIT COURT

The circuit court may exercise sound discretion in determining whether to impose a sanction following its finding of a violation of the discovery rules. Hutchins v. State, 339 Md. 466, 475, 663 A.2d 1281, 1286 (1995). The Supreme Court of Maryland held that the Appellate Court of Maryland erred in opining that the inadvertent nature of a violation could “in and of itself be dispositive” in holding whether there was an abuse of discretion. Mason v. State, 258 Md. App. 266, 281–82, 297 A.3d 642, 650–51 (2023). The Court re- affirmed that the circuit court must consider the prejudice suffered by the non-offending party. See, e.g., Thomas v. State, 397 Md. 557, 572, 919 A.2d 49, 58 (2007) (“[T]he [circuit] court’s evaluation of a discovery violation necessarily includes determining whether the violation has caused prejudice.”). Given that the circuit court has the discretion whether to impose a sanction, the Court held that “error correction” could justify the admission of evidence regarding items not disclosed in discovery, so long as the circuit court did not abuse its discretion in taking the action.

CRIMINAL LAW – MISTRIAL – ABUSE OF DISCRETION

“The grant of a mistrial is considered an extraordinary remedy and should be granted only if necessary to serve the ends of justice. While it is in the sound discretion of the trial judge to declare a mistrial, he or she may do so only if a high degree of necessity demands that he or she do so[.]” State v. Hart, 449 Md. 246, 276, 144 A.3d 609, 626 (2016) (quotation marks and citations omitted). The Supreme Court of Maryland held that Petitioner failed to establish that there was manifest necessity for a mistrial and thus, the circuit court did not abuse its discretion in denying the request, where Petitioner chose to elicit testimony regarding an item not disclosed in discovery, yet later argued he was prejudiced by this testimony.

CRIMINAL LAW – CURATIVE INSTRUCTION –ABUSE OF DISCRETION

“As a general rule, judges are accorded broad discretion in determining whether a particular instruction should be given on a particular occasion[.]” Carter v. State, 366 Md. 574, 584, 785 A.2d 348, 353 (2001). The Supreme Court of Maryland held that the circuit court did not err in applying Patterson v. State, 356 Md. 677, 741 A.2d 1119 (1999) and Cost v. State, 417 Md. 360, 10 A.3d 184 (2010) to the present case. The Court further held it was not an abuse of discretion for the circuit court to deny the request by Petitioner for a curative instruction, where the requested instruction was fairly covered by other standard instructions, or alternatively, the request was a motion to strike testimony elicited by the Petitioner. Circuit Court for Carroll County Case No.: C-06-CR-21-000610 IN THE SUPREME COURT Argued: February 6, 2024 OF MARYLAND

No. 21

September Term, 2023

_________________________________

TROY MASON

v.

STATE OF MARYLAND

Fader, C.J., Watts, Hotten,* Booth, Biran, Gould, Eaves,

JJ. _________________________________

Opinion by Hotten, J. _________________________________

Filed: May 30, 2024

*Hotten, J., now a Senior Justice, participated in the hearing and conference of this case while an active member of this Pursuant to the Maryland Uniform Electronic Legal Materials Act (§§ 10-1601 et seq. of the State Court. After being recalled pursuant to Government Article) this document is authentic. Maryland Constitution, Article IV, Section 2024.05.30 3A, she also participated in the decision 09:59:43 -04'00' and adoption of this opinion. Gregory Hilton, Clerk Troy Mason (“Petitioner”) was charged in the Circuit Court for Carroll County with

second-degree assault. During trial cross-examination of a law enforcement officer who

responded to the scene, both Petitioner and the State discovered that a “strangulation form”

supplied through discovery was not the original form completed at the scene. Initially,

Petitioner requested a curative instruction. Instead, the circuit court offered Petitioner an

opportunity to question the officer outside the presence of the jury, to which Petitioner

agreed. After questioning the officer and learning details regarding the alleged original

strangulation form, Petitioner elected to proceed with trial and “let the truth come out.”

The next day, Petitioner moved for a mistrial, and alternatively, requested a curative

instruction, both of which were denied.

Petitioner was convicted of second-degree assault and sentenced to ten years of

incarceration with all but seven years suspended and a period of supervised probation for

five years. The ensuing appeal arose from Petitioner’s request for a mistrial or curative

instruction. Mason v. State, 258 Md. App. 266, 272, 297 A.3d 642, 645 (2023). In a

reported opinion, the Appellate Court of Maryland (“Appellate Court”) affirmed the

conviction and the denial of a mistrial. Id. at 274, 297 A.3d at 646. The Appellate Court

analyzed the alleged prejudice sustained by Petitioner and concluded it did not warrant a

mistrial. Id. at 284–85, 297 A.3d at 651–53.

We granted certiorari to address the following questions which we have reworded1

for clarity as follows:

1 As certified, Petitioner presented the following three questions: (continued . . .) 1. Did the Appellate Court err in ruling that a mistrial was not required by virtue of the inadvertent nature of the discovery error?

2. Is “error correction” following a violation of the discovery rules a permissible justification for the admission of previously undisclosed evidence?

3. Did the circuit court abuse its discretion in denying Petitioner’s motion for a mistrial or curative instruction?

We answer Petitioner’s first two questions in the affirmative, but answer the third in the

negative, holding that the circuit court did not abuse its discretion and the Appellate Court

did not err in affirming.

(. . . continued) 1. Did the Appellate Court err in ruling that a mistrial was not required simply by virtue of the inadvertent nature of the discovery error?

2. Is “error correction” a legitimate reason to allow previously undisclosed evidence into trial, thereby excusing a discovery violation, where the new evidence contradicts information disclosed during discovery and previously relied on by the defense at trial?

3. Did the courts below abuse their discretion by finding no prejudice warranting a mistrial or curative instruction, where during discovery the State produce a blank Strangulation Supplement documenting no injuries to the complaining witness that was relied on by defense counsel at trial, and where surprise testimony revealed that the disclosed Supplement was erroneous and that the original Strangulation Supplement – which was not produced during discovery -- did document injuries.

2 FACTUAL AND PROCEDURAL BACKGROUND

Factual Background

On August 15, 2021, police officers responded to a 911 call reporting a domestic

disturbance at 81 ½ Pennsylvania Avenue in Westminster, Maryland. The responding

officers included Deputy Carbaugh (“Dep.

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Bluebook (online)
316 A.3d 529, 487 Md. 216, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mason-v-state-md-2024.