What Is Witness Intimidation

Document Sample
What Is Witness Intimidation
Justice in Jeopardy:

Victim and Witness

Intimidation in Maryland



Amy Anderson

Salisbury University



Elizabeth Krimmel

Johns Hopkins University



Yolanda Santirosa

Bowie State University



Lauren Trotta

University of Maryland Baltimore

County









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Police officers and prosecutors have become increasingly frustrated by their



inability to successfully investigate and prosecute criminal cases when key witnesses



refuse to provide critical evidence or to testify because for fear of retaliation by the



defendant or his family and friends.1



Witness intimidation has become so pervasive that it is ruining the public's faith



in the criminal justice system to protect them," said Judge John M. Glynn of Baltimore



City Circuit Court. "We are not much better off than the legal system in Mexico or



Colombia or some other sad places.2







What Is Witness Intimidation?

A witness is someone who has first-hand knowledge about a crime or dramatic



event and can help certify important considerations to the crime or event. A witness who



has seen the event first-hand is known as an eyewitness.3 Witness intimidation involves



witnesses crucial to court proceedings being threatened in order to pressure or extort



them not to testify. The refusal of key witnesses to testify commonly renders a case with



inadequate physical evidence void in a court of law.4



Witness intimidation includes threats against witness and victims of crimes and



strikes at the root of the criminal justice system. Witness intimidation denies critical









1

Finn, Peter, and Healy, Kerry Murphy. ―Preventing Gang- and Drug-Related Witness Intimidation‖ in

National Institute of Justice: Issues and Practices, November 1996,

http://www.ncjrs.org/pdffiles/163067.pdf (accessed on August 10, 2005)

2

New York Times, ―Guns and Jeers Used to Buy Silence‖, January 15, 2005,

http://www.gainesville.com/apps/pbcs.dll/article?AID=/20050116/ZNYT02/501160312/-1/wire02

(accessed on August 10, 2005).

3

Wikipedia, the Free Encyclopedia, s.v. ―Witness‖, http://en.wikipedia.org/wiki/Witness (accessed on

August 10, 2005).

4

Wikipedia, the Free Encyclopedia, s.v. ―Witness Intimidation‖,

http://en.wikipedia.org/wiki/Witness_intimidation (accessed on August 10, 2005)





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evidence to police investigators and prosecutors thus undermining the confidence of



whole communities in the government‘s ability to protect and represent them.



Intimidation is known to occur in areas more typically associated with high rates



of crime, such as inner cities, high density population areas and areas where co-operation



between the community and police has traditionally been poor. Offenders can create a



general atmosphere of fear and non-cooperation with the criminal justice system so that



while victims and witnesses of crime in the community may not be threatened directly,



their fear of reprisals is such that they are discouraged from reporting crime and/or from



giving evidence.5





The Nature of Victim/Witness Intimidation

Gang and drug-related intimidation may be case-specific or community wide.



The widespread intimidation of whole neighborhoods can be as detrimental to witness



cooperation as an explicit threat made against an individual. Each case-specific act of



violence against victims or witnesses promotes the community-wide perception that any



cooperation with the criminal justice system is dangerous.



Factors that contribute to the reluctance of witnesses to step forward include:



fear, strong community ties, or a deep-seated distrust of law enforcement. Community



members may also consider gang and drug crimes as outside the scope of their concern or



responsibility. Additionally, factors that increase the likelihood of intimidation include









5

Home Office Circular 12/01, May 15, 2001, http://www.homeoffice.gov.uk/docs/hoc0112.pdf (accessed

on August 10, 2005).





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the violent nature of the initial crime, a previous personal connection to the defendant,



geographic proximity to the defendant, and membership in a culturally vulnerable group.6



The need to provide for the safety of witnesses results from the constitutional



protections afforded criminal defendants. The Sixth Amendment of the U.S. Constitution



provides, in part, that "in all criminal proceedings, the accused shall enjoy the right to



confront the witness against him." Such protections were extended by the U.S. Supreme



Court to defendants in state proceedings through the ―Due Process Clause‖ of the



Fourteenth Amendment.



Some states require prosecutors to identify everyone "known by the government



[who has] knowledge of the relevant facts, while other states limit such disclosure only to



persons who will testify in trial or pretrial proceedings." Consequently, to protect



witnesses pre and post trial, and to preserve the integrity and effectiveness of the criminal



justice system, witnesses facing a threat to their personal safety are oftentimes either



incarcerated or placed under government protection.7



In most jurisdictions the problem of witness intimidation has begun to have a



major impact on the investigation and prosecution of crime, and there appear to be few



comprehensive, coordinated programs that address the issue. In Maryland, prosecutors,



police officers, judges, and victim advocates agree that witness intimidation is



widespread, increasing, and has serious impact on the prosecution of crime. State, county,









6

―Tackling Witness Intimidation--an Outline Strategy,‖ The Criminal Justice System of England and

Wales, http://www.cjsonline.org.uk/library/pdf/witness_intimidation_strategy.pdf (accessed on August 10,

2005).

7

Kash, Douglas A. ―Hiding in plain site: a Peek into the Witness Security Program‖, The FBI Law

Enforcement Bulletin, May 2004, http://www.findarticles.com/p/articles/mi_m2194/is_5_73/ai_n7068945

(accessed on August 10, 2005)





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and city jurisdictions must begin to plan comprehensive and formal programs in order to



successfully combat this issue.8



Types of Intimidation

There exist two principal types of witness intimidation:



Overt intimidation occurs when someone does something explicitly to intimidate



a witness into withholding, changing, or falsifying testimony. Most overt



intimidation occurs only when there is a previous connection between the



defendant and the victim, and when they live relatively close to each other.



Actual examples of overt intimidation include:





The sister of a defendant slaps a witness outside the courtroom and says

she will kill her if she testifies.



Two gang associates of a defendant drive by a witness‘s apartment, slash

his car tires, and smash the windshield.





An incarcerated defendant puts the word out on the street through fellow

gang members that a murder witness will be killed if he cooperates with

the prosecution.



Implicit intimidation involves a situation in which there is a real but unexpressed



(or indirectly expressed) threat of harm to anyone who may testify. Implicit



intimidation is often community-wide in nature and is characterized by an



atmosphere of fear and non-cooperation generated by a history of violent



retaliation against cooperating witnesses or by a cultural mistrust of the criminal



justice system.9 Actual examples of implicit intimidation that have prevented



witnesses from coming forward include:





8

Kash.

9

Finn and Healy.





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A drug-related shooting occurs at a softball game; three players are killed

in full view of spectators, but no cooperative witnesses can be found.



Two individuals suspected of stealing money from the homes of

Vietnamese immigrants are arrested, but the victims all claim they did not

see the faces of the perpetrators.



Oftentimes witnesses feel intimidated even when there is no actual danger. Overt



intimidation, implicit intimidation, and misperceived intimidation may operate separately



or in parallel. Furthermore, each instance of actual intimidation or violence against



witnesses promotes the community-wide perception that any cooperation with the



criminal justice system is dangerous.



Overt intimidation, because it may be publicized widely in the press or by word of



mouth, may contribute to an exaggerated perception of the risk of injury. Community-



wide and misperceived intimidation can be as harmful to witness cooperation as explicit



threats. A public perception that the criminal justice system cannot protect the citizens of



a community is as effective in destroying the ability of police investigators and



prosecutors to do their jobs as any specific threat. As a result, prosecutors, police



administrators, and victim/witness program administrators need to prevent all types of



intimidation.





How Serious Is Witness Intimidation?

No one knows the precise extent of witness intimidation because only limited



scientific research has been conducted on the problem.10 However, most of the





10

Connick, E., and R.C. Davis, ―Examining the Problem of Witness Intimidation,‖

Judicature 66 (1983): 439–447; and Davis, R.C., ―Victim/Witness Intimidation in the Bronx Courts: How

Common Is It, and What Are Its Consequences?‖ unpublished monograph, New York: Victim Services

Agency, 1990.







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prosecutors, police officers, judges, and victim advocates agreed that witness intimidation



is widespread, that it is increasing, and that it seriously affects the prosecution of violent



crimes.



We had the opportunity to speak with Sandy Bromley, Esquire/Staff Attorney,



and Tracy Delaney, from the Maryland Crime Victims' Resource Center, Inc. The



following is an excerpt taken from that interview:





Question: What are some of the major obstacles in protecting a witness without violating the

defendant's rights?



Answer: Our entire system of justice is premised on the notion that a defendant is innocent until

proven guilty. Furthermore, the U.S. Constitution, as well as state constitutions, provides

enumerated rights for defendants such as the right to legal counsel, the right to a fair trial, and the

right to confront the witnesses against them. Some people incorrectly believe that we are trying to

interfere with a defendant‘s constitutional rights. This is not correct, as attorneys and legal

advocates we are sworn to uphold the law, and certainly we agree and respect that defendants have

rights.



Our position is that this is not a zero sum game, meaning if you afford a victim any right then that

somehow detracts from the rights afforded to the defendant. This is incorrect logic. If this logic is

applied to victims who wish to assert their rights, this must also be applied to the State in criminal

cases and the plaintiff in a civil case to say that if you give the State or a plaintiff the right to be

heard in court, to be present at trial and to be represented by legal counsel then you have somehow

detracted from the defendant‘s rights. As you know, the State or plaintiff absolutely have the right

to be present at the trial, represented by legal counsel and informed about the proceeding so the

notion that this violates the defendant‘s rights is absurd. The same logic applies to victims; the

notion that allowing victims to be informed about the proceedings in their case, to be present at the

trial, to be represented by legal counsel and to be heard somehow detracts from the defendant‘s

rights is equally preposterous.



However every day we are told that victims of crimes have no right to be informed about the

proceedings, hearing, motions, etc. That they have no right to be heard through giving a victim

impact statement, and that we as attorneys have no place in the court room to represent the victim

and ensure that their rights are not violated. All of this occurs even thought Article 47 of the









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Maryland Declaration of Rights, as well as several other statutory provisions, require these rights

for victims! Many times the excuse is that to allow these things would somehow violate the

defendant‘s rights.



Question: I understand a watered- down version of Senate Bill 188, the witness protection bill,

passed during the current legislative session. What were portions of the original bill made it into

the final version?



Answer: The original version of Senate Bill 188 prohibited a person from harming, threatening to

harm or soliciting another person from harming or threatening to harm a person or property with

the intent to induce a victim or witness not to testify. It provided the exact prohibitions of

harming, threatening or soliciting another to do so in retaliation against a victim or witness for

giving testimony.



This bill was amended to remove all of the provisions related to prohibiting a person from

harming, threatening to harm or soliciting another person from harming or threatening to harm a

person or property with the intent to induce a victim or witness not to testify or in retaliation for

testifying. It further removed the provisions related to intimidating court officials, jurors, etc.



The original version also prohibited intimidation, influencing, or impeding an officer of the court,

juror, or potential witness and made any of the acts above a felony. The bill as introduced also

contained a hearsay exception to any testimony offered against a party that engaged or acquiesced

in wrongdoing that was intended to and did procure the unavailability of a witness. The

introduced version of the bill allowed the court to determine the admissibility of the statement.



Question: Is witness intimidation a state-wide problem? Or, only in the Baltimore/DC area? Or

only in Baltimore City? Also, does it occur only in capital murder cases, or in other kinds of

cases as well?



Answer: Witness intimidation occurs all over the state of Maryland, as it is not necessarily crime

specific. It may be more prevalent with respect to drug related charges or crimes where there is a

huge penalty at stake (for example, capital murder; felony drug murder, etc.) so perhaps it is

prevalent, or concentrated as the case may be, in high drug traffic areas, i.e. urban areas such as

Baltimore and DC. However, witness intimidation happens quite often in Domestic Violence

cases. Girlfriends/Wives are often intimidated into dropping charges and/or not testifying against

their offenders. This type of intimidation is not often as widely reported as say a gang situation as

there may not be a murder involved, but more threats and manipulation that are a result of the

imbalance of power in the relationship as evidenced by the initial crime.









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Explanations for the Recent Increase in Victim/Witness Intimidation

J. Ramsey Johnson, Assistant U.S. Attorney for the District of Columbia states, ―In my



view the reasons for this dramatic increase in fear and intimidation are many and varied.



The defendant we prosecute for committing violent crime is not only much younger than



in the past, but very often displays several commonly-held attitudes and beliefs,



including:





A profound lack of respect for authority.



The expectation that their own lives will be brief or will be lived out in prison.



A sense of powerlessness and social inadequacy that can lead to the formation of

gangs or neighborhood crews.



The ready availability of very powerful firearms.



A willingness to use those firearms for almost no reason or in retaliation for the

most minimal slight to their extraordinarily fragile egos.



Lastly, and ironically, the increased penalties being imposed on those convicted

of violent crime, which can raise the stakes of a prosecution.‖11





The Most Likely Targets of Intimidation

Anyone is a potential victim of intimidation, however, there exist four factors that



increase the chances that a witness will be intimidated. These include:



The initial crime was violent.



The defendant has a personal connection to the witness.

The defendant lives near the witness.







11

Johnson, J. Ramsey, Assistant U.S. District Attorney for the District of Columbia, Statement Before the

Subcommittee on Crime and Criminal Justice, Committee on the Judiciary, U.S. House of Representatives,

August 4, 1994





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The witness is especially vulnerable—for example, he or she is elderly or a recent

or illegal immigrant.



Residents of gang-dominated neighborhoods often fall into more than one of these



categories, greatly increasing their exposure to intimidation. Incarcerated witnesses and



juvenile witnesses are also especially vulnerable to intimidation. Offenders easily



identify witnesses who are in jail or prison, and because they cannot hide, they are easy



prey to other inmates, including the defendants in the case at hand or defendants‘



associates or family members.



Juveniles are an especially vulnerable group because they are often less able or less



willing to take precautions against being located by would-be intimidators, and because



they are more susceptible to family or peer pressure not to testify. Relocated juveniles



may endanger themselves by contacting old friends and visiting old neighborhoods.



Juveniles may also be less able to take advantage of witness security measures, even



where these are available, because minors not living with both parents may not relocate



out of state, or in extreme cases, change their identity, without the consent of the non-



custodial parent.12





Documented Incidents of Victim/Witness Intimidation in Maryland

In 1997, Amy Lynn Fischer, 26, a clerk in an Annapolis-area photo store, was

scheduled to appear as a witness in a shoplifting case involving two packs of film

worth $35.98. The night before the trial, the defendant shot Ms. Fischer and her

sister as they pulled into their driveway.



In 2002, a drug dealer admitted to setting fire to the Dawson family home in

retaliation for the family‘s reported calls to police about drug dealing in their

neighborhood. The resulting fire claimed the lives of Carnell Dawson, Angela

Dawson, and their five young children.







12

Finn and Healy.





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In November 2002, Baltimore City Police Detective Thomas Newman was

assassinated in retaliation for testifying against the half brother of one of his

killers, who was put on trial for wounding Newman in a 2001 shooting.



Rickey Prince, a 17-year-old Baltimore County homicide witness, was kidnapped

and shot in the head by two friends of the murderer in 2003 a few days after a

prosecutor read Mr. Prince's name aloud in a packed courtroom.



Tjane C. Marshall, the murderer of a pregnant Howard County woman, told

witness Rashall Wall that he would be killed if he testified. The victim was found

shot four times in the face, lying in bed at her suburban apartment in Columbia‘s

Oakland Mills Village in May 2003.





Baltimore City Judge Glynn recalled that one witness, a middle-aged woman

who witnessed the killing of a bail bondsman by a drug dealer, was so scared she

could not open her mouth on the stand. 13



In January 2004, four men barged into Anthony Black‘s home, pointed their guns

at his fiancé and 10-year-old son, and threatened to kill them if Black testified

about their East Baltimore drug ring.14



Intimidation in the Courtroom

One area of intimidation that is of particular concern is the intimidation of victims



and witnesses in and around the courtroom. This common form of intimidation occurs



when friends, relatives, and/or associates of a defendant pack the courtroom with the



precise purpose of frightening victims and witnesses. Intimidation of this nature is often



very subtle, and as a result, can easily be missed by judges, bailiffs, and attorneys in the



courtroom.15 When victims and witnesses are intimidated, the justice system cannot be



successful in fairly prosecuting criminals; important cases are dismissed due to lack of



testimony and evidence, and in return guilty criminals are set free.





13

New York Times.

14

Steele, Michael S., Lt. Governor, before the United States House of Representatives, Committee on

Government Reform, Subcommittee on Criminal Justice, Drug Policy, and Human Resources, May 2,

2005, http://reform.house.gov/UploadedFiles/Lt.%20Gov%20Steele%20Testimony.pdf (accessed on

August 10, 2005).

15

Finn and Healy.





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As more and more cases are lost due to issues of witness intimidation, frightened



citizens and communities believe that law enforcement is powerless to protect them.16



This conspiracy for silence has led to a number of cases being dismissed, and guilty



criminals serving less time in prison, and ultimately being released back into the



community unwarrantedly. Prosecutors and judges say that, intimidation has ingrained



itself in Baltimore‘s judicial system…and there‘s evidence of it everywhere: in recorded



wiretap conversations, in interviews with petrified victims and in courtrooms



themselves.17



In 2003, Wesley Adams, a homicide prosecutor for the State‘s Attorney of



Baltimore City, said that of the nine homicides he tried, ―23 of the 35 witnesses he



managed to get to the stand either recanted or lied, and that was not counting the many



others who were too scared and simply disappeared.‖18 In addition, in the last year, the



Baltimore City state‘s attorneys offices has seen nearly ninety nonfatal shootings



prosecuted and dismissed because of witness problems, the majority involving issues of



intimidation.19



In a specific case of intimidation in the courtroom, Adams reports that in a recent



murder case he prosecuted, ―about a dozen young men wearing what‘s considered the



‗street uniform‘ of blue jeans and whit t-shirts filled the courtroom‘s two back benches.



One female witness visibly shuddered throughout her testimony, and clenched her teeth



so hard that her face swelled up.‖20 Unfortunately this is not an isolated case of







16

Bykowicz, Julie. ―Fight Witness Intimidation,‖ in The Baltimore Sun,. February 17, 2005.

17

Bykowicz, Julie. “Another Weapon in War on Witnesses,” in The Baltimore Sun, December 12, 2004.

18

New York Times.

19

The Baltimore Sun, ―Conspiracy of Silence,‖ February 16, 2004.

20

Bykowicz, “Another Weapon.”





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courtroom intimidation, and judges often have to stop trials in order to calm frightened



witnesses.



Reducing Intimidation in the Courtroom



There are however, actions judges can legally take to avert intimidation in the



courtroom. Case law supports limited courtroom closure or spectator exclusion to prevent



witness intimidation, as well as segregating spectators in the courtroom.21



Judges in Baltimore sometimes-confiscate cell phones to prevent courtroom



observers from instantly sending messages that relay witness or case information directly



to people on the streets. 22 Simply being aware of intimidating spectators and gang



members in the courtroom, and being proactive in the enforcement of a no tolerance



witness intimidation policy can help to eliminate intimidation in the courtroom.



General courtroom and courthouse procedures can be implemented to help



eradicate victim and witness intimidation. In cases where victims and witnesses are



reluctant to testify in front of the defendant, a live television link between the courtroom



and a separate room where the witness, accompanied by a court officer, is situated may



be utilized; in other cases, screens and voice distorters could be used allowing the judge,



counsel and jury to see the witness, but not the suspect or spectators.23



Often intimidation is a direct result of proximity of the intimidator and witness,



and as a result, intimidation can occur in waiting areas of court buildings. To help



eliminate intimidation in the courthouse, separate waiting facilities can be designed to







21

Finn and Healy.

22

Bykowicz, “Another Weapon.”

23

Laycock, Gloria, ed. ―Witness Intimidation: Strategies for Prevention,‖ in Crime Detection and

Prevention Series, No. 55 (1994) http://www.homeoffice.gov.uk/rds/prgpdfs/fcdps55.pdf (accessed July 26,

2005).





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separate victims, witness and their associates from defendants and their associates.24



When separate waiting facilities are not available, non-uniformed officers can monitor



these areas.



Judges are not the only advocates to prevent witness intimidation in the



courtroom; attorneys and bailiffs must participate in eliminating witness intimidation as



well. Attorneys and bailiffs, when aware of intimidation in the courtroom, can bring



intimidation to the judge's attention and make it clear that the court is empowered to



remove, and prosecute, intimidators. Prosecutors often have authority to prevent



intimidation through techniques such as requesting exclusion of daunting spectators, and



impeaching their own witnesses, should they change their testimony before, or at, the



trial. In order to make witnesses feel comfortable, a prosecutor may need to ask a judge



if someone can accompany a witness in the courtroom, especially during testimony.



Attorneys and bailiffs can also take action outside of the courtroom to prevent the



intimidation of witnesses such as, discouraging gang members and intimidating



spectators from entering the courtroom—arrest those with outstanding warrants, use



videotapes in the courtroom, and utilize metal detectors and pat-down searches before



entering the courtroom; and escorting and accompanying witnesses.25 Methods of



questioning and taking testimony from witnesses, case investigation, and contact with



witnesses outside of the courtroom must also be conducted in a manner which does not



intensify or create additional threat or danger to the witness.



It is advisable that judges and attorneys are aware of the steps available to



alleviate witness intimidation. From courtroom procedures to petitions for sealing





24

Laycock.

25

Finn and Healy.





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documents, those in the legal profession must be conscious of accessible resources to aid



in the protection of witnesses.



Though judges, bailiffs and attorneys play important roles with respect to



intimidation in the courtroom, they are only able to act within the realms the legislature



and laws allow them to. With many victims and witnesses disappearing due to threats



from defendants and their associates, legislation is necessary to secure and preserve their



testimony, and utilize it as evidence. This can be accomplished through legislation



allowing statements to be submitted from witnesses who cannot be produced; the



Supreme Court, based on the principle that a defendant cannot benefit from his/her own



misconduct, has upheld this hearsay exception.26 This tool available to federal



prosecutors would be extremely useful on the state level, as attorneys say intimidation is



far more prevalent in state courts than at the federal level. 27 If state prosecutors are given



the tools necessary to conduct cases effectively they can better fulfill their duty to keep



our communities safe.



By reducing intimidation in the courtroom, cases can be tried fairly; prosecutors



will be able to contact and rely on victims and witnesses without fear of losing evidence



and vital testimony, and victims and witnesses will be able to testify without fear of



retaliation. Intimidation in the courtroom is a hindrance to the justice system and must be



addressed aggressively in order to be eliminated.





Witness Intimidation in Correctional Facilities

Many new programs in Maryland are currently being implemented to protect



witnesses testifying at trials while no initiative currently aims at eliminating one main

26

The Baltimore Sun, ―Don‘t Delay,‖ January 20, 2005.

27

Bykowicz, “Another Weapon.”





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source of witness intimidation, the threat presented by convicted felons housed in



correctional facilities. There are twenty-six prisons in Maryland, ranging from minimum



to maximum security, with a total of 27,702 inmates in the state. 28 The main threat that



they represent is their ability to reach people on the outside to ‗do their dirty work‘ to



intimidate those connected to carrying out prosecution of their case. Another major



problem that the prisons are also faced with that fuels the problem of harassing witnesses



is the influx of contraband, mainly consisting of drugs and cellular telephones.



A new tactic being used by some prosecutors to ensure the testimony of some



witnesses is jailing a witness until their testimony is complete. In September 2004,



Baltimore City established a detective unit to find witnesses who refuse to testify and



haul them off to jail if they it find necessary. A member of the new unit, Detective Byron



Conaway, said that as of April 2005 about twenty-five reluctant witnesses have been



jailed so far. These individuals are usually only held for a few days, but that is not



always the case. One prosecutor shared an experience where one of his witnesses who



were incarcerated due to the fear of testifying was brought to jail in the same vehicle as



the defendant, who passed a threatening note.29 This should not be a viable solution for



forcing people to testify. If proper procedures were put in place to protect witnesses from



incarcerated individuals then there would not be such a disinclination to testify.



Three stories recently seen in the news are excellent examples of how inmates are



arranging to silence witnesses of their felonies by attempting to hire fellow inmates to



murder key witnesses involved in their trials. If a defendant kills or silences a witness to



28

Maryland Department of Public Safety and Corrections , ―Statistics,‖,

http://www.dpscs.state.md.us/aboutdpscs/statistics.shtml (accessed on June 20, 2005).

29

Witte, Brian. ―Witness Intimidation: A Crisis,‖ ABC News Online, April 22, 2005,

http://abcnews.go.com/US/print?id=694775 (accessed on June 20, 2005).







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his or her crime then incriminating statements given to police and the grand jury are



inadmissible at trial. Although a bill very recently passed in Maryland allows for



‗hearsay‘ in some circumstances, it does not permit incriminating evidence in all cases



which allows some guilty parties to escape prosecution.



In July 2004, DeAndre Whitehead was acquitted of murder charges that alleged



he shot a man named Russell Peterson outside of his Southwest Baltimore row house.



Peterson‘s daughter, Tashiera, witnessed the murder. While incarcerated prior to the



murder trial, Whitehead was recorded by a wiretap offering his cellmate drugs and money



to kill Tashiera and her mother, Patricia, in addition to offering up their locations.



Although the maximum penalty for murder-for-hire is 10 years, a deal was struck with



federal prosecutors in which Whitehead will serve 6 years in return for pleading guilty to



one of two counts of soliciting to commit a crime of violence. One of the main reasons a



deal was reached meant that Patricia and her terrified daughter would not have to testify



at the trial.30



Another similar incident occurred in February 2005, when a man named Joshua



Anthony Mumford, awaiting trial on armed robbery and attempted murder charges, told



his cellmate that he wanted to have two witnesses in his case killed and asked him



whether he ―has someone who can take care of something like that‖. Mumford‘s



cellmate alerted the police who convinced him to wear a digital recording device. During



the taped conversation, Mumford tried to persuade his cellmate that the witnesses in his



trial could not be kidnapped and held for a while, but had to be killed. The cellmate



made a phone call and had Mumford talk to a county homicide detective posing as



30

Dolan, Matthew. ―Man to Plead Guilty in Bid to Have Girl, 11, Killed,‖ Baltimore Sun, April 12, 2005,

www.baltimoresun.com/news/local/crime/bal-gir0412,1,5769446.story?coll=bal-local-utility, (accessed on

June 20, 2005).





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someone named ―KC‖ trying to arrange payment for the contract murder. When



Mumford could not make arrangements for the $1500 payment, he agreed, ―to kill



anyone for [the cellmate] or his friends when he gets out of jail‖, according to court



documents. One Baltimore County police officer commenting on the recording said, ―He



reiterates that he wants the witnesses murdered‖. Mumford was charged in the



solicitation-for-murder case in Baltimore County and faces up to life in prison if



convicted. Another trend reinforced by this circumstance is that witness intimidation is



not only a problem in Baltimore City. Jason G. League, an assistant Baltimore County



state‘s attorney, reflecting upon the case said, ―It is my experience that traditionally we



have not had a problem with witness intimidation in Baltimore County. However, times



are a-changin‘.‖ In a few months time these two inmates, Joshua Anthony Mumford and



DeAndre Whitehead, were both caught on tape soliciting murder-for-hire of the witnesses



in their trials, so one must wonder daily how many inmates are attempting to orchestrate



the same arrangements, considering prosecutors in Baltimore City alone handle 300



nonfatal shootings and 120 fatal shooting cases each year.31



One of the most famous and more recent cases in Baltimore County is that of



Christopher Bacote, a Morgan State University freshman who pled guilty to first-degree



murder in the shooting death of a 23-year old man. Nine months after Bacote was



charged with murder, he was also charged with obstruction of justice after his finger



prints were matched to those found on a threatening letter left in the mail slot of a family



home of a college student who also received a threatening cell phone message on his cell





31

McMenamin, Jennifer. ―Murder Suspect Charged with Soliciting Killing of Witnesses,‖ Baltimore Sun,

February 20, 2005, www.baltimoresun.com/news/local/crime/bal-county0202,1,7099820.story?coll=bal-

local-utility, (accessed on June 20, 2005).







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phone. Baltimore County police and prosecutors believe that Bacote was behind the



phone message as well as a series of threatening letters mailed from the Baltimore



County Detention Center while he was awaiting trial.32



Steps to Reduce Witness Intimidation in Correctional Facilities



One major threat presented by those incarcerated is the accessibility to cellular



telephones. A total of 121 cell phones were recorded on contraband reports for only nine



examined facilities, which does not include the additional seventeen facilities throughout



the state. Although cell phones are considered contraband within the facilities and thus



deemed strictly prohibited, they still find their way into the hands of inmates. In two



maximum-security Jessup prisons alone (the Maryland House of Corrections and the



Annex), 92 cell phones were confiscated in a ten-month period. The presence of cell



phones allows inmates to arrange drug deals or to continue direct outside criminal



enterprises while serving time in prison. Many union officials believe more contraband



has been getting into the prisons in the past year because of staffing cuts and employee



turnovers.33



Several alternatives exist that may be pursued to decrease the number of cell



phones permeating through the correctional facilities in Maryland, which include a better



screening process of all who enter and exit through the premises, a zero-tolerance policy



regarding gang members, a more aggressive approach to attacking the significant



presence of drugs in the institutions, and mandating more funding to correctional





32

McMenamin, Jennifer. ―Suburbs See Some Cases of Threats Against Witnesses,‖ Baltimore Sun, April 7,

2005, www.baltimoresun.com/news/local/crime/bal-threats0407,1,4584186.story?coll=bal-local-utility,

(accessed on June 20, 2005).

33

Garland, Greg. ―Contraband Floods Maryland Prisons,‖ Baltimore Sun, July 6, 2005,

www.baltimoresun.com/news/local/bal-te.md, (accessed on July 6, 2005).







- 19 -

institutions to man their guard towers. The main recommendation offered in this paper,



however, includes establishing a special cell searching task force in every medium and



maximum-security jails throughout the state.



A specialized cell searching task force should be established whose primary



responsibility is seeking out cell phones and drugs hidden in the inmates‘ cells. Each



maximum and medium security should have a three-man team with post orders that



consist of searching cells daily. Particular emphasis should be placed upon those inmates



who have committed especially violent crimes, repeat offenders of violent crimes, and



those with a past history of intimidating witnesses or jury tampering. Members of



security threat groups, individuals who for the most part are associated with a group that



poses a threat to the security of others and to the institution itself, should also be subject



to more intensive and scrutinized searches. Correctional officers are burdened with many



responsibilities that do not allow them to search inmate cells as often as they should and



could be, so the creation of this team will help to alleviate time discrepancies in an effort



to prevent witness intimidation by way of early detection of a problem. The average cost



of employing a member of the new Contraband Cell Searching Force would be about



$37,914, which is based on the average salary of a maintenance correctional officer with



a minimum pay of $29,944 and a maximum salary of $45,884. There are eight medium



security jails and three maximum-security jails under the supervision of the Division of



Corrections, which should each, have the new task force implemented. The cost of



establishing the new force at each institution would be $113,742, with a total projected



cost of $1,251,162.34 One prosecutor in Washington D.C. reported success in





34

―Statistics,‖ Maryland Department of Public Safety and Corrections,

http://www.dpscs.state.md.us/aboutdpscs/statistics.shtml, (accessed on June 20, 2005).





- 20 -

discovering victim and witness intimidation by executing search warrants in prison when



defendants were arranging an intimidation scheme through written correspondence with



family or gang members on the outside. With a team dedicated just to this cause,



preventing witness intimidation inside facilities, Maryland may experience success in



thwarting plots to intimidate witnesses.



Drugs are significant regarding witness intimidation because they are a major



source of payment used in exchange for one‘s service of intimidating witnesses. In the



late 1980s, the proliferation of a new drug of choice, crack cocaine, coaxed by a steady



heroin market on Baltimore‘s street corners combined with an arsenal of illegal guns,



created a surge in loosely knit, violent drug-trafficking organizations that used guns to



dispense street justice. Today, this violence has a deadly grip on Baltimore, with a



corresponding increase in street justice and witness intimidation.35 A former inmate who



spent significant time in many Maryland prisons said, ―That‘s what everything in the



whole prison is about- drugs. Almost all the violence and stuff is based on the drugs.‖ A



former director of Virginia‘s prison system said inmates are adept at exploiting any



opening to obtain drugs or other forbidden items: ―They are always listening, always



watching.‖ As an example, he said, a prisoner may overhear one officer complain to



another about debt he owes. The inmate might later approach the officer with an offer to



earn some easy money by helping get contraband inside. Baltimore law enforcement



officials even estimate that 50 to 60 percent of the city‘s homicides are related to drug



dealing, and drug offenses are the leading reason for incarceration of state prisoners



convicted of crimes committed in Baltimore. According to a July 2000 assessment by the





35

Jessamy, Patricia. ―Fight Witness Intimidation,‖ Baltimore Sun, February 17, 2005,

www.stattorney.org/wiarticle01.html, (accessed on July 6, 2005).





- 21 -

U.S. Drug Enforcement Administration (DEA), Baltimore is the ―most heroin-plagued



area‖ in the nation and faces one of the most severe crack problems as well.36 A better



screening process of searching people who come through facilities may drastically reduce



the amount of drugs and cell phones being brought into the facilities. This more strict



screening process would not only apply to visitors, but also correctional officers and



other staff. According to Frank C. Sizer Jr., the Correction Commissioner, visitors,



volunteers, support staff, and officers who are insufficiently vigilant or are dishonest are



all means by which drugs and other contraband can get into a prison. He also said, ―The



fact of the matter is that we have some staff that are corrupt‖.37 Although some



undependable people may slip through the cracks and become hired at the correctional



facilities, some steps may be taken to reduce these instances from occurring. A more



rigorous process of searching all who enter a facility may ensure that less contraband is



being brought into the correctional facilities.



Gangs are quite prevalent throughout the correctional system as well, and they



maintain ties with their fellow gang members on the outside while they are incarcerated.



Due to uninterrupted connections between incarcerated individuals and neighborhood



gang members, victims and witnesses no longer feel that imprisonment of the defendant



pending trial or after conviction can ensure their safety in the community. The



knowledge that gangs have easy access to members of the community deters many



witnesses at once. Some gangs are said to hire attorneys to represent incarcerated



witnesses who may be in custody as a result of the crime in question or on another



36

―Treating Baltimore‘s Drug Problem,‖ Smart Steps, www.drugstrategies.org/Baltimore/BaltCh_2.html,

(accessed on July 6, 2005).

37

Garland.









- 22 -

unrelated charge. The gangs hire these lawyers without the witness‘ knowledge or



consent in an effort to control the witness‘ testimony.38 Jerry Estes, a member of the



board of the National District Attorney‘s Association said, ―Any time you have organized



crime—and gang activity is a form of organized crime—you will have a code of silence



and intimidation elements involved.‖ A city homicide prosecutor, E. Wesley Adams,



recalled a young Baltimore man, Adrian Tony Jenkins, who witnessed an associate shoot



and beat a man who urinated on gang turf in May 1999. Jenkins identified the shooter as



Andre ―Turtle‖ Chavis. After Chavis was arrested, he penned letters from his jail cell to



associates, and included copies of Jenkins‘ typed statement to police. ―Tony Rat….. got



to die because, yo, he can‘t be trusted.‖39 All correctional facilities should institute strict



zero-tolerance policies towards gangs and gang members. This should include separating



known gang members and not allowing them to associate at any time, in addition to



closely monitoring their phone calls and any other form of correspondence. They should



be a main focal point of the Special Cell Searching Force‘s jurisdiction, being subject to



daily cell ‗shakedowns‘ or searches.



Although some of the suggestions mentioned in this paper may seem expensive or



intangible, a simple and inexpensive alternative may be to better open the communication



between law enforcement officers, prosecutors, and the judiciary. Law enforcement



officers are better positioned than prosecutors to foresee and prevent intimidation at the



street level. Law enforcement officers should inform prosecutors about repeat offenders



and potential intimidators, alert prosecutors to potential witnesses who are being







38

Finn and Healy.

39

Gately, Gary. ―Baltimore Struggles to Battle Witness Intimidation,‖ The Boston Globe , February 12,

2005, www.stattorney.org/wiarticle02.html, (accessed on July 06, 2005).





- 23 -

intimidated, and reduce gang income and intimidation by disrupting gang operations with



intensive policing tactics.



It may even be helpful to have police officers visit the families of potential



intimidators and explain the laws concerning obstruction of justice.40 Based on the



serious nature of the problem, putting justice in jeopardy because of the lack of people



willing to testify in criminal cases, more extreme measures should be put in place, such



as a special cell searching task force, implementing more strict searches of all who travel



through the correctional facilities in Maryland, and instituting a zero-tolerance gang



policy. If these suggestions are implemented they may help to drastically reduce the



amount of cell phones, drugs, and gang activity in correctional facilities throughout the



state of Maryland, which will in turn make a more comfortable atmosphere for witnesses



to testify. I urge you to not let justice be in jeopardy any longer, but to act preventatively



to thwart any future hindrance of prosecution by protecting innocent victims and



witnesses.





Why Do We Need to Implement Stricter Policies?

Witness intimidation continues to be an impediment to the effective prosecution



of violent crimes, especially in jurisdictions where witnesses are reluctant to testify for



fear of their lives.41 Since the October 16, 2002 firebombing of the home of East



Baltimore residents Angela and Carnell Dawson which killed the couple and their five



children, and the recent release of a ―Stop Snitching‖ DVD warning that people could be



killed for cooperating with the police, witness intimidation has continued to pervade





40

Finn and Healey.

41

Delegate Vallario, et al., HB 748: ―Criminal Law – Intimidation of Witnesses‖, Maryland General

Assembly, 2005 Session.





- 24 -

almost every aspect of criminal cases, as reported by city prosecutors.42 Unfortunately,



without the ability to ensure protection of those who have witnessed violent crimes



involving some of Maryland‘s most dangerous drug dealers, prosecuting the state‘s most



violent criminals will become increasingly difficult.



Models for Successful Victim/Witness Protection Programs



Without the creation and implementation of a more structured and far-reaching



witness protection policy, individuals willing to report criminal activity and testify in



court will continue to be threatened, harassed, and even killed for their cooperation.



Despite recent state and federal efforts, which have taken important steps to curbing the



threats and violence directed towards witnesses and informants, witness intimidation is



still a pervasive and serious issue. State‘s Attorney Patricia C. Jessamy said, ―Witness



intimidation—ranging from threatening gestures inside courtrooms to more blatant



attacks that leave witnesses injured or dead—is like a plague in Baltimore.‖43 Baltimore



prosecutors have said that these types of threats have made it increasingly difficult to



convict criminals and that ―about one-quarter of last year‘s gun cases . . . were dropped



because direct or perceived threats created problems with testimony.‖ 44





More effective law enforcement and prosecution is a necessary component to



reducing credible threats against witnesses, and the State of Maryland has an obligation



to its citizens to effectively protect them against such actions. For the State of Maryland



to produce an effective witness protection, it is necessary to look towards witness



protection programs in Rhode Island, California, Colorado, and Ohio, as well as the





42

Dolan.

43

Bykowicz, Julie. ―O‘Malley Testifies on Witness Protection,‖ in The Baltimore Sun, May 3, 2005.

44

WJZ-Channel 13 News, ―Stop Snitching T-shirts on Sale‖, April 30, 2005.





- 25 -

highly successful Federal Witness Security Program (WITSEC) run by the U.S. Marshals



Service, which has, since its inception, protected over 7,500 witnesses and more than



9,500 family members, and the federal Emergency Witness Assistance Program (EWAP).



Individuals who are part of state run programs enjoy range of comprehensive services.



The Rhode Island Victim Services Unit, run through the State‘s Attorney General‘s



Office, informs witnesses and victims of their rights, notifies them of the status of their



case, assists them in court, and helps them to better understand the legal process. ―In



addition, the unit provides referrals to other agencies and support groups that can provide



further assistance with financial, legal, medical, or emotional problems resulting from the



crime.45





Additionally, the State of Maryland should look to another highly successful and



comprehensive program, the California Witness Protection Program. ―Administered by



the Department of Justice, the California Witness protection Program provides funding to



district attorneys to ensure the safety of witnesses whose testimony is crucial to obtain



criminal convictions.‖ 46 A comprehensive publication titled, ―Help for Victims of



Crime,‖ provided by The State of California Office of Victims‘ Services offers a detailing



both victim/witness rights, and a full range of services available to protect and assist



them. Simply educating victims and witness on their rights, and assisting them through



the prosecution and trial phase, can serve to protect these individuals from becoming









45

State of Rhode Island: Office of the Attorney General ―Victim Services,‖

www.riag.ri.gov/criminal/victim.php, (accessed on July 24, 2005).

46

State of California: Office of the Attorney General ―Attorney General Lockyer, Prosecutors, Urge

Continued Funding of Witness Protection Program,‖ http://ag.ca.gov/newsalerts/2003/03-036.htm

(accessed on July 25, 2005).





- 26 -

victims of retaliation. Additionally, it provides information on Victim Witness Centers



by county so that individuals seeking such services have easy access.





The WITSEC program has been highly successful, and has achieved an overall



conviction rate of 80 percent resulting from protected witnesses‘ testimonies.47 WITSEC



offers witnesses and their family‘s new identities, housing, medical care, job training, and



employment, and most importantly, ―24-hour protection to all witnesses while they are in



a high threat environment, including pre-trial conferences, trial testimonials and other



court appearances.‖48 Additionally, no individuals participating in WITSEC who follow



security guidelines have ever been harmed. It can be assumed, that if replicated in the



state of Maryland, that, if offered such comprehensive services such as those outlined by



the U.S. Marshals Service, both prosecutors and witnesses would enjoy higher levels of



success in trying and convicting dangerous criminals and protecting those who testified



against them.





The federal Emergency Witness Assistance Program, created in 1997―to address the



need for immediate, non-protective, short duration witness assistance not available



through the Witness Security Program,‖49 offers U.S. Attorney‘s Offices with the ability



to assist witnesses and potential witnesses on an emergency basis. Unlike WITSEC,



EWAP does not provide any protective services; it solely provides emergency monetary



assistance and services to help relieve witness fears and concerns. The services provided







47

United States Marshals Service ,―Witness Security Program,‖, www.usmarshals.gov/witsec, (accessed on

July 21, 2005).

48

United States Marshals Service

49

U.S. Department of Justice , ―The Emergency Witness Assistance Program,‖

www.usdoj.gov/oig/reports/EOUSA/e0102/intro.htm#progback, (accessed on July 21, 2005).





- 27 -

by EWAP to U.S. Attorney‘s Offices are low-cost (approximately $4,000), and usually



limited to 30 days. These services include:





Transportation

Temporary Housing/Moving Expenses

Temporary Subsistence

Miscellaneous Expenses up to $250 (for items such as window security, locks, or

repairs)

Emergency telephone services

Child or Elder Care50



Even though EWAP only provides a temporary solution for witness protection, in many



cases these services can be sufficient in protecting these potential victims. With a low



price tag, the implementation of a program similar to EWAP is not beyond the means of



the State of Maryland.





Additionally, state prosecutors have agreed upon two urgent needs to address the



increased levels of threats and intimidation that have hindered the successful prosecution



of violent crime in Baltimore and throughout Maryland. These are 1) Changing the state



law and maximum penalty for witness intimidation and urging state lawmakers to provide



the same legal tools available to federal prosecutors, and 2) the need to locate and pursue



missing witnesses to bring them to court to allow cases to be successfully prosecuted.51



With an effective witness protection program similar to that provided by the federal



government, prosecutors are sure to receive significantly higher rates of cooperation



among witnesses, and will subsequently enjoy rising conviction rates as a result.









50

U.S. Department of Justice.

51

Office of the State’s Attorney for Baltimore City, ―Congressional Field Hearing—Witness Intimidation‖,

May 2, 2005.





- 28 -

Conclusion

Witness intimidation continues to provide a serious threat to public security, and the



State of Maryland has a responsibility to its citizens to provide adequate protection from



these threats. By modeling itself off of the highly successful Federal Witness Security



Program, and on other state-run programs throughout the country, Maryland would surely



enjoy high levels of witness security, which will have important long-term consequences



for witness and public safety.





In summation, it is recommended that a number of policies should be implemented in



order to achieve the successful protection of victims and witnesses of violent crime.



These include:





1. The creation of a Task Force within the Maryland State Police to address issues of

witness protection and security. In extreme cases, this Task Force would be

responsible for providing 24-hour protection to witnesses of serious and violent

crime while they are in a high-threat environment.



2. A comprehensive guide, much like that of the State of California, to provide

witnesses with a clear definition of their rights, and how they can protect

themselves against threatening individuals.



3. A comprehensive relocation program that can assist witnesses in cross-town or

cross-county relocation. This includes: moving expenses, assistance enrolling

children in new schools, assistance in accessing medical and community

resources, counseling to assist individuals and families in adjusting to their new

environment, and, in extreme cases, monetary assistance until they can obtain new

employment, and assistance obtaining new employment.



4. The creation of a ―Cell-Searching Task Force‖ at every medium and maximum

security prison. These Task Forces will be comprised of three team members.

This should cost approximately $113,742 at each of the eleven facilities in the

State of Maryland, for a total cost of $1,251,162.



5. Have police officers visit the homes of potential intimidators' families

to warn them of the penalties of obstruction of justice.







- 29 -

6. Mandate more monies to medium and maximum correctional facilities for higher

levels of security to monitor all incoming persons for contraband.



7. The implementation better searching procedures for all individuals entering

correctional facilities to ensure they are not bringing contraband inside the

facility.









- 30 -

Works Cited



Bykowicz, Julie. “Another Weapon in War on Witnesses,” in The Baltimore Sun,

December 12, 2004.



Bykowicz, Julie. ―Fight Witness Intimidation,‖ in The Baltimore Sun,. February 17,

2005.



Bykowicz, Julie. ―O‘Malley Testifies on Witness Protection,‖ in The Baltimore Sun,

May 3, 2005.



Connick, E., and R.C. Davis, ―Examining the Problem of Witness Intimidation,‖

Judicature 66 (1983): 439–447; and Davis, R.C., ―Victim/Witness Intimidation in the

Bronx Courts: How Common Is It, and What Are Its Consequences?‖ unpublished

monograph, New York: Victim Services Agency, 1990.



Dolan, Matthew. ―Man to Plead Guilty in Bid to Have Girl, 11, Killed,‖ Baltimore Sun,

April 12, 2005, www.baltimoresun.com/news/local/crime/bal-

gir0412,1,5769446.story?coll=bal-local-utility.



Finn, Peter, and Healy, Kerry Murphy. ―Preventing Gang- and Drug-Related Witness

Intimidation‖ in National Institute of Justice: Issues and Practices, November 1996,

http://www.ncjrs.org/pdffiles/163067.pdf .



Garland, Greg. ―Contraband Floods Maryland Prisons,‖ Baltimore Sun, July 6, 2005,

www.baltimoresun.com/news/local/bal-te.md.



Home Office Circular 12/01, May 15, 2001,

http://www.homeoffice.gov.uk/docs/hoc0112.pdf.



Johnson, J. Ramsey, Assistant U.S. District Attorney for the District of Columbia,

Statement Before the Subcommittee on Crime and Criminal Justice, Committee on the

Judiciary, U.S. House of Representatives, August 4, 1994



Kash, Douglas A. ―Hiding in plain site: a Peek into the Witness Security Program‖, The

FBI Law Enforcement Bulletin, May 2004,

http://www.findarticles.com/p/articles/mi_m2194/is_5_73/ai_n7068945.



Laycock, Gloria, ed. ―Witness Intimidation: Strategies for Prevention,‖ in Crime

Detection and Prevention Series, No. 55 (1994).



Maryland Department of Public Safety and Corrections, ―Statistics,‖

http://dpscs.state.md.us.









- 31 -

McMenamin, Jennifer. ―Suburbs See Some Cases of Threats Against Witnesses,‖

Baltimore Sun, April 7, 2005, www.baltimoresun.com/news/local/crime/bal-

threats0407,1,4584186.story?coll=bal-local-utility.



New York Times, ―Guns and Jeers Used to Buy Silence‖, January 15, 2005,

http://www.gainesville.com/apps/pbcs.dll/article?AID=/20050116/ZNYT02/501160312/-

1/wire02.



Office of the State’s Attorney for Baltimore City, ―Congressional Field Hearing—

Witness Intimidation,‖ May 2, 2005.



State of Rhode Island: Office of the Attorney General, ―Victim Services,‖

www.riag.ri.gov/criminal/victim.php.



State of California: Office of the Attorney General, ―Attorney General Lockyer,

Prosecutors, Urge Continued Funding of Witness Protection Program,‖

http://ag.ca.gov/newsalerts/2003/03-036.htm.



Steele, Michael S., Lt. Governor, before the United States House of Representatives,

Committee on Government Reform, Subcommittee on Criminal Justice, Drug Policy, and

Human Resources, May 2, 2005,

http://reform.house.gov/UploadedFiles/Lt.%20Gov%20Steele%20Testimony.pdf.



The Baltimore Sun, ―Conspiracy of Silence,‖ February 16, 2004.



The Baltimore Sun, ―Don‘t Delay,‖ January 20, 2005.



The Criminal Justice System of England and Wales, ―Tackling Witness Intimidation--an

Outline Strategy,‖

http://www.cjsonline.org.uk/library/pdf/witness_intimidation_strategy.pdf.



United States. Department of Justice, ―The Emergency Witness Assistance Program,‖

www.usdoj.gov/oig/reports/EOUSA/e0102/intro.htm#progback.



United States Marshals Service, ―Witness Security Program,‖,

www.usmarshals.gov/witsec.



Vallario (Maryland State Delegate), et al., HB 748: ―Criminal Law – Intimidation of

Witnesses‖, Maryland General Assembly, 2005 Session.



Wikipedia, the Free Encyclopedia, http://en.wikipedia.org.



Witte, Brian. ―Witness Intimidation: A Crisis,‖ ABC News Online, April 22, 2005,

http://abcnews.go.com/US/print?id=694775.



WJZ-Channel 13 News, ―Stop Snitching T-shirts on Sale‖, April 30, 2005.







- 32 -


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