Supreme Court of Maryland
Belton v. State
May 31, 2023483 Md. 523
Summary
The Supreme Court of Maryland held that the erroneous exclusion of the decedent’s statement, “This is my block,” was not harmless because the statement could have affected the jury’s assessment of the objective reasonableness of Belton’s fear in deciding self-defense. The Court reversed Belton’s manslaughter and firearm convictions and ordered a new trial on those counts, while affirming his concealed-handgun conviction. The Court announced that due-process protections requiring impartial judges extend to appellate proceedings but declined to decide whether the intermediate appellate court’s language actually violated those protections because the harmless-error ruling required a new trial.