A Maryland appellate court has overturned a manslaughter conviction against a man in a case in which a North Bethesda woman was killed and her body set on fire in 2018.
Stephan Leroy H. Lunningham, then 29, was charged with killing Angela “Paris” Fay Thomas, 49, after her body was found in a residential area in Germantown on March 14, 2018.
In June 2019, a jury convicted Lunningham of voluntary manslaughter and arson charges, but acquitted him of first- and second-degree murder charges.
Lunningham appealed the verdict to the Maryland Court of Special Appeals in 2019 on the grounds that police induced a confession from him during an interview.
Lunningham also contended that the suppression of testimony from a doctor during the trial prevented the jury from hearing about Lunningham’s drug addiction and mental state at the time of the killing.
In an opinion on Tuesday, an appellate court three-judge panel rejected Lunningham’s argument that his confession was involuntary, but agreed that not allowing the doctor’s testimony had an effect on the case.
The appellate panel overturned the manslaughter conviction, but upheld the arson conviction. The case has been remanded to Circuit Court for further proceedings, and the possibility of a revised sentence.
Drug addiction and connection to dealer preceded killing
Lunningham became addicted to crack cocaine in 2017 and started to buy it that year from Thomas, who was a crack dealer in the Germantown area, according to the Court of Special Appeals’ opinion.
From March through October of that year, Lunningham drove Thomas to do errands or pick up food, and his addiction to the drug caused his mental health to decline, the opinion said.
In November 2017, Lunningham went to a drug rehabilitation facility and completed the program within a month, according to documents. He then went for counseling. By January 2018, he was taking college classes and had started a new job.
However, the following month Lunningham relapsed into addiction and stopped going to class and the outpatient recovery center.
Lunningham drove Thomas into Washington, D.C., to get drugs on March 11, 2018, according to the opinion.
When the two were headed back to Maryland, Lunningham took a detour, which upset Thomas. Thomas hit Lunningham in the face and chest while he drove, and pulled a knife from the glove compartment, according to documents.
The opinion states that Thomas swung the knife as Lunningham pulled over the car. He blocked her arm and stabbed Thomas multiple times as she fought back. Lunningham continued to stab Thomas until she died.
Lunningham drove around Germantown with Thomas’s body for the next three days, the opinion states. He moved her body to the back seat, took money out of her bank account, got gas and tried to kill himself “several times,” according to documents.
On March 14, after getting gas a second time, he poured gas into the car with Thomas’s body in it and lit it on fire.
First responders came to extinguish the fire and police found Thomas’s body in the back seat of the car, documents state. They started investigating her death as a homicide, then charged Lunningham with murder and arson on March 21, 2018.
A medical examiner determined that Thomas’s body had 19 stab wounds and 23 cutting wounds, most of which would not normally be fatal. The more likely cause of death was blunt force trauma to Thomas’s skull and the fact that her wounds were not treated, the opinion states.
A jury convicted Lunningham of voluntary manslaughter and second-degree arson in June 2019. He was sentenced to 25 years in prison.
According to the opinion, Lunningham confessed to killing Thomas and burning her car; the interrogation by police lasted nearly four hours, following his arrest.
Lunningham made a motion to suppress statements he made to police during the interview, but the court denied the motion in May 2019.
The opinion also states that prosecutors at the time filed a motion to prevent Lunningham from offering expert testimony from a doctor who could speak about Lunningham being diagnosed with an “unspecified depressive disorder,” cannabis use disorder and cocaine use disorder, as well as how his illnesses affected his mental state.
The court granted the state’s motion to withhold the testimony before the trial.
Lunningham said in the appeal that he thinks expert testimony would have helped the jury understand his mental state at the time of the killing, while prosecutors said the testimony lacked a “nexus” to his mental state.
Lunningham filed an appeal of the jury’s verdict in October 2019 on the grounds that his statements during the police interrogation were not voluntary, and that the court erred in excluding the expert testimony about his illnesses and mental state at the time of the killing.
Judge Douglas Nazarian wrote in the opinion for the Court of Special Appeals, released on Tuesday, that the Montgomery County Circuit Court found that Lunningham’s vital signs were normal at the time of the interrogation, he was sober and his demeanor showed “an absolutely appropriate level of distress.”
Nazarian wrote that the circuit court found that detectives did not induce Lunningham’s confession and that there was no error in the determination that his statements to police were voluntary.
Lunningham raised the issue in his appeal of “perfect” self-defense, meaning that expert testimony might have proven that he thought there was a threat of deadly or serious harm at the time of the killing and that Lunningham did not use excessive force, according to the opinion.
Nazarian wrote that because there is no dispute that Thomas brandished a knife at Lunningham, a jury could reasonably conclude that he thought he was in danger at the time. He also wrote that a jury could conclude that Lunningham did not use excessive force toward Thomas, based on the medical examiner’s testimony that she died from a combination of injuries.
Nazarian wrote in the opinion that expert testimony from a doctor “would have assisted the jury’s assessment of Mr. Lunningham’s mental state, particularly whether and to what extent he acted in self-defense,” the opinion states.
“The psychological profile testimony, therefore, could provide a baseline against which the jury could measure the objective reasonableness of Mr. Lunningham’s response and actions,” Nazarian wrote.
Nazarian went on to write in the opinion that had the jury heard the expert testimony on Lunningham’ s psychological profile, “we cannot say beyond a reasonable doubt that the jury would not have found perfect self-defense.”
Dan Schere can be reached at firstname.lastname@example.org