State v. WilsonAnnotate this Case
The Court of Appeals held that the evidence in this case was sufficient to support Defendant's convictions for witness tampering and obstruction of justice where Defendant married a witness for the State with the corrupt intent of having her invoke the spousal testimonial privilege at his upcoming murder trial.
The evidence indicated that Defendant married a potential witness for the State in order to have the witness invoke the spousal testimonial privilege at his murder trial. Before trial, the circuit court granted the State's motion to preclude the witness from invoking the spousal testimonial privilege. A jury subsequently found Defendant guilty of witness tampering and obstruction of justice. The Court of Special Appeals reversed, concluding that the evidence was insufficient to support the convictions because State failed to prove the "corrupt means" element of the convictions. The Court of Appeals reversed, holding (1) when a person marries a potential State witness with the intent to enable the witness to invoke the spousal testimonial privilege at a criminal proceeding the evidence is sufficient to support convictions for witness tampering and obstruction of justice; and (2) Defendant's conviction for witness tampering did not merge for sentencing purposes with his obstruction of justice conviction.