Riggins v. State

Nearly forty years ago, the Court of Appeals held that a defendant in a criminal case has a due process right to inspect prior written statements made by prosecution witnesses that are in possession of the State. Carr v. State, 284 Md. 455, 472-73, 397 A.2d 606 (1979). Two years later, this Court held that this right existed independently of the State’s duties imposed by the criminal discovery rules. Leonard v. State, 46 Md.App. 631, 636-37, 421 A.2d 85 (1980), aff'd, 290 Md. 295, 429 A.2d 538 (1981). This appeal requires us to apply the principles of Carr and related decisions to decide…