State v. Smith

Summary

The Supreme Court of Maryland held that Smith adequately preserved his objection to the trial court’s admission of an entire 55-minute interview under the declaration-against-penal-interest hearsay exception. The trial court was required to parse the interview statement by statement and determine whether each statement was genuinely self-inculpatory, and defense counsel’s objections sufficiently challenged the court’s failure to perform that analysis. The court affirmed the Appellate Court’s judgment.