Brief Brief. Sessoms v. State, 357 Md. 274 (2000).
Issue: The test for admitting other crimes evidence, under Maryland Rule 5-404, does not apply to other crimes or wrongs committed by anyone other than defendant.
“We hold that the test for admitting other crimes evidence in criminal proceedings enunciated in Faulkner generally does not apply to crimes, wrongs, or acts committed by someone other than a criminal defendant. The other crimes evidence rule is a court-created standard designed to ensure that a defendant is tried for the crime for which he or she is on trial and to prevent a conviction based on reputation or propensity to commit crimes, rather than the facts of the case. Because this rule is premised upon protecting an accused from undue prejudice, it does not apply to exclude other crimes evidence involving alleged actions by others testifying in the criminal proceedings. This is especially so when the evidence is crucial to the defense in a criminal proceeding and concerns impeachment of a witness with a possible prejudice, bias, interest, or motive to falsely testify.” (Id. at 294).