Supreme Court of Maryland

Gross v. State

August 26, 2022481 Md. 233

Summary

The Court reaffirmed that Maryland harmless-error review asks whether the reviewing court can conclude beyond a reasonable doubt that the error in no way influenced the verdict, without requiring proof of other overwhelming and largely uncontroverted evidence. It also held that the cumulative nature of erroneously admitted evidence is a relevant consideration and concluded that admitting the June video was harmless because the victim’s account was repeated through several other sources, DNA evidence corroborated the allegations, and the defense itself used the video to support its theory. The Court therefore affirmed the judgment below; a dissent argued that the majority improperly speculated about what the jury would have decided without the video.