Supreme Court of Maryland

Gross v. State

August 26, 2022

Summary

The court reaffirmed Maryland’s beyond-a-reasonable-doubt harmless-error standard and held that the State need not prove additional prerequisites such as overwhelming and largely uncontroverted evidence. It also held that the cumulative nature of erroneously admitted evidence remains relevant to harmless-error review. Applying that framework to the full record, the court concluded that admitting the June video did not contribute to the guilty verdict and affirmed.