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State v. Pratt

Court of Appeals of Maryland
398 A.2d 421 (1979)


Facts

The State of Maryland (plaintiff) prosecuted Margaret Melton Pratt (defendant) for murdering her husband. Pratt claimed she was legally insane at the time. At trial, two of the five or more psychiatrists who examined Pratt after the killing accepted Pratt's claim. Over Pratt's objection, the State called Dr. Brian Crowley, another psychiatrist who examined Pratt. Crowley testified that originally, Pratt's own counsel retained him to conduct the examination, but that nevertheless the examination persuaded Crowley that Pratt was not legally insane at the time of the killing. In closing arguments, the State emphasized how Crowley would not give defense counsel the testimony counsel expected, and suggested counsel may have retained many experts before finding two who would say Pratt was insane. The jury found Pratt guilty. Pratt appealed to the Court of Special Appeals on the grounds that Crowley's testimony violated the attorney-client privilege. The court agreed and ordered a new trial. The State appealed to the Court of Appeals of Maryland.

Rule of Law

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Issue

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Holding and Reasoning (Digges, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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