Simms v. State

This seemingly straightforward drug case has morphed into a criminal procedure exam question. Leonard Lee Simms was charged in the Circuit Court for Anne Arundel County with theft of services from a hotel and with possession with intent to distribute heroin, possession of heroin, possession with intent to distribute ethylone, 1 possession of ethylone, possession of cocaine, and conspiracy to distribute heroin (this last charge was later amended to conspiracy to distribute methy-lenedioxymethamphetamine (“MDMA”)). After an unsuccessful suppression hearing, Mr. Simms proceeded to trial on an…