Browne v. State

Summary

The Supreme Court of Maryland held that evidence of the defendant’s prior conviction for the fatal abuse of his infant son was inadmissible under Maryland Rule 5-404(b). The evidence did not establish a sufficiently distinctive modus operandi, rebut a genuinely contested claim of accident, or support a permissible inference under the doctrine of chances apart from propensity. The court reversed and remanded for a new trial.