Ragland v. State

Appellant Jeffrey Ragland was convicted of distribution of a controlled dangerous substance in violation of Md.Code (2002, 2003 Cum.Supp.), § 5-602 of the Criminal Law Article. At trial, two police officers offered “lay opinion” testimony, based on their training and experience, that a particular series of events had constituted a drug transaction. Ragland appeals, arguing that such evidence should only have been admitted as expert testimony, subject to the accompanying qualification and discovery procedures. We agree, and accordingly we shall vacate the conviction and remand the case for a…