Simmons v. State

Stephen Simmons, appellant, was charged with first-degree murder and related offenses in the Circuit Court for Prince George’s County. Appellant’s trial began on August 12, 2010. In his opening statement, defense counsel disclosed that appellant had offered to take a lie detector test. The court sustained the State’s objection and gave a curative instruction.

Two days later, after the State’s presentation of four witnesses, the prosecutor moved for a mistrial based on defense counsel’s opening statement disclosing appellant’s offer to take a lie detector test. The court granted the State’s…