State v. Payne & Bond

State of Maryland v. Joseph William Payne & Jason Bond, No. 85, Sept. Term 2013, Opinion by Battaglia, J. EVIDENCE – SUBJECT OF EXPERT TESTIMONY UNDER RULE 5-702 – TECHNICAL PROCESSES Trial court erred by allowing a police officer, who was not qualified as an expert under Maryland Rule 5-702, to testify as to the location of the cell phone towers through which the defendants’ cell phone calls were routed as determined by his analysis of the defendants’ cell phone records, because such testimony requires that the witness be qualified as an expert. EVIDENCE – HEARSAY EXCEPTIONS – PARTY OPPONENT…