In Simmons v. State, the defendant was convicted of second-degree murder after raising an imperfect self-defense claim based on his subjective belief that deadly force was necessary to avoid imminent harm; the trial court excluded proposed expert psychiatric testimony that would have addressed whether that belief was consistent with Simmons's psychological profile. The Court of Special Appeals affirmed the conviction, but the Court of Appeals reversed, holding that the issue of admissibility was preserved and that the trial judge erred as a matter of law by categorically barring the evidence. The core reasoning was that such limited expert testimony is relevant to the existence of the required subjective belief without usurping the jury's role in assessing credibility or the facts, and its exclusion may have prevented the jury from considering a lesser offense. The court remanded for a new trial.

criminal lawprocedure