As previously discussed in this blog, in the spring of 2014, the Maryland Court of Special Appeals in State v. Hailes,[1] made important rulings regarding several evidentiary issues. The Hailes court held that a “hard blink” can be a statement, that a “Dying Declaration” does not require actual imminent death, only a belief of imminent death, and that the Confrontation Clause of the Sixth Amendment does not suppress a dying declaration.[2] After further appeal, the Court of Appeals of Maryland recently affirmed that decision.