Muhammad v. State

In this appeal we hold that the Circuit Court for Baltimore City erred by admitting into evidence, as a prompt complaint of sexual assault, a factually detailed prior consistent statement of a sexual assault victim; and that the error was not harmless beyond a reasonable doubt.

Melvin Caldwell, a/k/a Kamal Muhammad, the appellant, was charged with numerous crimes arising out of the stabbing of L.M. in a vacant row house in Baltimore City. A jury convicted him of attempted second-degree murder, first-degree assault, second-degree assault, possession of a deadly weapon with intent to injure, and…