Rainey v. State

Robert Rainey v. State of Maryland, No. 54, September Term, 2021. Opinion by Hotten, J. CRIMINAL LAW – JURY INSTRUCTION – DESTRUCTION OR CONCEALMENT OF EVIDENCE A destruction or concealment of evidence jury instruction, like any consciousness of guilt jury instruction, requires the State to provide “some evidence” to support a chain of four inferences (“Thompson inferences”) connecting the destruction or concealment of evidence to actual guilt. In the case at bar, the State requested and, the circuit court gave, a destruction or concealment of evidence jury instruction based on the defendant…