State v. Payne
Annotate this CaseJoseph Payne and Jason Bond were convicted in a joint trial of first degree murder and kidnapping. The Supreme Court vacated the judgment of the circuit court and remanded the case for a new trial, holding (1) the trial court erred in admitting the testimony of a police officer, without the officer having been qualified as an expert witness under Maryland Rule 5-702, regarding his process for determining the communication path of Defendants’ cell phones and his conclusion that two particular cell towers were the most pertinent to the case; and (2) wiretap statements made by Bond but not Payne could not be admitted against Payne as statements by a party opponent.
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