Sample v. StateAnnotate this Case
The Court of Appeals affirmed Defendant's conviction of attempted robbery with a dangerous weapon and other crimes, holding that the circuit court did not abuse its discretion in admitting social media evidence because there was sufficient circumstantial evidence under Maryland Rule 5-901(b)(4) for a reasonable juror to find that Facebook profiles belonged to Defendant and to Defendant's alleged accomplice.
During trial, a detective testified that Defendant unfriended his accomplice on Facebook the day after the attempted armed robbery, in which the accomplice was fatally shot. On appeal, Defendant argued that there was insufficient circumstantial evidence for a reasonable juror to find that the Facebook profile belonged to him and that he used his profile to unfriend the profile purportedly belonging to his accomplice. The Court of Appeals affirmed, holding that, under the circumstances, there was sufficient circumstantial evidence for the trial court to allow the Facebook-related evidence to be presented to the jury.