Brooks v. State

Wardell Monroe Brooks v. State of Maryland No. 46, September Term 2013 Evidence - Impeachment of Witness - Prior Inconsistent Statement. To impeach a witness with extrinsic evidence of a prior allegedly inconsistent oral statement, a party must satisfy the conditions set forth in Maryland Rule 5-613. If the only extrinsic evidence offered is a written summary of the prior oral statement, it must be a substantially verbatim version of the oral statement unless the witness who made the oral statement has previously adopted or ratified the writing as an accurate summary of the prior oral…