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State V. Ayala

In: Other Topics

Submitted By valex10
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Ayala v. Maryland (Cite as: 174Md.App.647 (2007) )

Appellant Ayala was convicted in a jury trial in the Circuit Court, Prince George County C. Phillip Nichols Jr. J of a first degree murder and sentence to life in prison. Appellant do not denied that he was involved in the murder; however, he did it as a self-defense not because it was a gang affiliation.

Was the admissibility of gang evidence in the trial accurate?

The Court of Special Appeals, Davis J. affirm the decision made by the Maryland State Court to found admissible the evidence of the appellant’s gang affiliation.

The Court of special appeals affirm the decision made by the the Maryland State Court because it can be little doubt that evidence that a defendant is a member of an organization known for violent acts may be evidence of bad character or prior bad acts. See generally Klauenberg v. State, 355 Md. 528, 547-49, 735 A.2d 1061 (1999) (where the Court of Appeals discussed what constitutes a bad act and commented in dicta that in some cases decided by courts of other jurisdictions “membership in a gang was considered a bad act”). Under Md. Rule 5-404(b):

The Court of special appeals has explained that One of the purposes for which other crimes evidence may be admitted under Rule 5-404(b) is to prove motive. Motive is the catalyst that provides the reason for a person to engage in criminal activity․ “Like intent, motive is a mental state, the proof of which necessarily requires inferences to be drawn from conduct or extrinsic acts.”

People v. Davis, 335 Ill.App.3d 1, 268 Ill.Dec. 829, 779 N.E.2d 443 (2002), the defendant was convicted of murder, attempted murder, and a related firearm charge in connection with an attack on a group of people who were sitting on a porch. The prosecution theorized that defendant and accomplices, who were...

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