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Published on 12/3/2024, 12:23:00 PM

Evidence of Good Character: A Powerful Defense in Maryland Criminal Trials

In Maryland criminal trials, defendants are presumed innocent until proven guilty beyond a reasonable doubt. While the prosecution must prove the charges, the defense can leverage evidence of the defendant's good character to create reasonable doubt about their guilt. Maryland Pattern Jury Instruction MPJI-Cr 3:20 highlights how this evidence is presented and considered by the jury.

What Does Character Evidence cover?

The Maryland Pattern Jury Instruction MPJI-Cr 3:20 allows the introduction of evidence regarding a defendant's good character traits relevant to the charges. For example:

  • Honesty and integrity may be highlighted in cases involving fraud or theft.
  • Non-violence and peaceability could be introduced in cases involving assault or other violent crimes​:contentReference[oaicite:0]{index=0}.

This evidence is intended to show the defendant's propensity to act lawfully, thereby creating doubt about their involvement in the alleged offense.

When Can You Use Good Character Evidence?

Cases Where Good Character Evidence is Admissible

Evidence of good character is admissible in cases where specific traits directly relate to the charges. Examples include:

  1. Theft and Fraud Cases: Demonstrating honesty and integrity can suggest the defendant is unlikely to commit acts of deception or theft.
  2. Drug Distribution Cases: Evidence of a law-abiding nature may support claims that the defendant would not knowingly engage in illegal drug activity.
  3. Infamous Crimes: Common law felonies like murder, manslaughter, robbery, rape, burglary, larceny, arson, sodomy and mayhem open the door for a Defendant to put on good character evidence.

Cases Where Good Character Evidence May Not Apply

Character evidence may not be effective or admissible in situations where it is irrelevant to the charge or overshadowed by other factors. Examples include:

  1. Strict Liability Crimes: Offenses such as DUI or possession of contraband often do not involve intent, making good character evidence less impactful.
  2. Firearm Cases: Possession offenses like felon in possession of a firearm don't involve character at all.
  3. Assault Charges: Second Degree Assault charges similarly do not open the door to character evidence.

The judge ultimately decides whether good character evidence is relevant and permissible in each case.

Presenting Evidence of Good Character

To use this defense effectively, character evidence can be introduced through:

  1. Character Witnesses: Testimonies from individuals familiar with the defendant's reputation in their community or personal interactions.
  2. Reputation Evidence: Statements about the defendant's general reputation in a specific context, such as their workplace or neighborhood.

Under Maryland law, character evidence must be directly relevant to the crime charged and presented by credible witnesses.

Limitations on Character Evidence

While powerful, evidence of good character has its limitations:

  1. Relevance: Evidence must pertain to the traits relevant to the charges. For instance, a defendant's honesty may not be relevant in a case involving violent assault.
  2. Cross-Examination: The prosecution can challenge the credibility of character witnesses, often by introducing prior actions or statements that contradict the good character claims.
  3. No Guaranteed Outcome: While persuasive, character evidence is not determinative and must be weighed alongside all other evidence in the case.

How This Defense Impacts the Jury

MPJI-Cr 3:20 instructs jurors to consider evidence of good character as it relates to the likelihood of the defendant committing the crime. It emphasizes that such evidence may be sufficient to create reasonable doubt, even if the prosecution presents other compelling evidence.

FAQs

Q: Can evidence of good character alone lead to an acquittal?

A: Yes, if it raises reasonable doubt about the defendant's guilt. However, the jury considers it alongside all other evidence.

Q: Can prior bad acts negate good character evidence?

A: The prosecution may present evidence of prior bad acts to challenge the credibility of character witnesses, subject to the judge's approval.

Q: How do you choose effective character witnesses?

A: Select witnesses who can credibly speak to the defendant's reputation in areas relevant to the charges.

Conclusion

Introducing evidence of a defendant's good character can be a pivotal strategy in Maryland criminal cases. By leveraging MPJI-Cr 3:20, skilled attorneys can effectively use this evidence to instill reasonable doubt in the minds of jurors.

If you or a loved one is facing criminal charges, the experienced attorneys at FrizWoods can help craft a defense tailored to your circumstances. Learn more about our criminal defense services or contact us for a free consultation today.