JOSEPH LEON HALL, JR. v. STATE OF MARYLAND
Court of Appeals, Watts, Filed March 25, 2014,
Jury Instruction- Anti-CSI- It is an abuse of discretion to give an “anti-CSI effect” jury instruction where the defendant does not misstate the law.

Still on the anti-anti-CSI-effect crusade, the Court of Appeals once again finds abuse of discretion in giving an “anti-CSI effect” instruction. Judge Watts wrote the dissent in Robinson, stating in that case that she believed that the defense misrepresented the State’s burden.
J. Watts now writes the majority opinion in Hall and holds that while the instruction was improperly given, it was harmless beyond a reasonable doubt given the evidence presented (both sides agreed that the defendant was driving the victim’s car; they had different explanations as to why).