Wheeler v. Maryland

163 A.3d 843 (2017)

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Wheeler v. Maryland

Maryland Court of Special Appeals
163 A.3d 843 (2017)

Facts

Undercover detective Ivan Bell bought heroin from Robert Wheeler (defendant). Bell received the drugs in three bags from Wheeler’s associates: two orange Ziploc bags and one clear Ziploc bag with blue writing on it. Bell returned to the police station and wrote a report about the incident. The report was identified with a complaint number. The bags were the only drugs that Bell bought on the day in question. Wheeler was charged with conspiracy to distribute heroin and distributing heroin. At trial, the police chemist who tested the drugs and confirmed they were heroin testified that he had received two orange Ziploc bags and one clear Ziploc bag with blue writing on it, all contained in one package. That package had the same complaint number on it as was on Bell’s report. The prosecution (plaintiff) did not call as a witness the officer who put the three Ziploc bags in the package and sent it to the lab. Wheeler challenged the admissibility of the drug evidence, arguing that the prosecution did not properly authenticate it. The trial court overruled the objection and convicted Wheeler. Wheeler appealed.

Rule of Law

Issue

Holding and Reasoning (Albert, J.)

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