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MUHAMMAD v. STATE

No. 826, September Term, 2014.

115 A.3d 742 (2015)

223 Md. App. 255

Kamal MUHAMMAD a/k/a Melvin Caldwell, v. STATE of Maryland.

Court of Special Appeals of Maryland.

May 29, 2015.

Attorney(s) appearing for the Case

Wyatt Feeler (Paul B. DeWolfe, Public Defender, on the brief), Baltimore, MD, for appellant.

Benjamin A. Harris (Brian E. Frosh, Atty. Gen., on the brief), Baltimore, MD, for appellee.

Panel: DEBORAH S. EYLER, ARTHUR, FRIEDMAN, JJ.

In this appeal we hold that the Circuit Court for Baltimore City erred by admitting into evidence, as a prompt complaint of sexual assault, a factually detailed prior consistent statement of a sexual assault victim; and that the error was not harmless beyond a reasonable doubt.

Melvin Caldwell, a/k/a Kamal Muhammad,...

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