Supreme Court of Maryland

Carver v. State

December 20, 2022

Summary

The Supreme Court of Maryland affirmed the denial of Steven Carver’s petition for a writ of actual innocence. The Court held that materiality must be assessed cumulatively in the context of the entire trial, including admitted evidence, evidence available but unused or excluded, and trial strategy, but concluded that Carver’s evidence did not undermine confidence in the verdict. The Court determined that evidence of an alternate perpetrator was speculative, that a posttrial expert opinion was not newly discovered, and that a witness’s unserved warrants could have been discovered earlier and were immaterial.