Alarcon-Ozoria v. State
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The Court of Appeals affirmed the judgment of the court of special appeals affirming Defendant's conviction of illegal possession of a firearm, holding that there was no error.
Specifically, the Court of Appeals held (1) the scope of the State's mandatory disclosure obligations pursuant to Md. Rule 4-263(c)(2) does not include jail call recordings held by a state correctional facility that has not reported to the State in a particular case; (2) under the circumstances of this case, the State exercised due diligence in disclosing the jail call recordings; and (3) even if the State violated its discovery obligations through its late disclosure, the error was harmless.
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