State v. Bircher

STATE OF MARYLAND v. JACOB BIRCHER
Court of Appeals, Battaglia (Plurality), Feb. 23, 2016,
Jury Instruction – Supplemental Instruction – Where supplemental instruction introduced new prosecution theory, upheld where defendant was allowed supplemental closing argument and no prejudice occurred.

(Dissent – Watts, Barbera and Adkins Join – Supplemental jury instruction has a “special potential for prejudice” and did so in this case)
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