Supreme Court of Maryland

Woodlin v. State

July 26, 2023

Summary

The Supreme Court of Maryland held that CJP § 10-923(e)(4) does not require courts to consider any particular factor when balancing the probative value of other sexually assaultive behavior against unfair prejudice, although courts may consider a nonexclusive range of factors. It affirmed the admission of Woodlin’s prior sexual-assault conviction because the motions judge reasonably determined that its probative value was not substantially outweighed by unfair prejudice. The Court also held that Woodlin waived any challenge to the scope of the evidence because he never asked either circuit court judge to limit the details presented. No separate opinions were filed.