In Garner v. State, 183 Md. App. 122, 145, 960 A.2d 646 (2008), aff'd, 414 Md. 372, 995 A.2d 694 (2010), the Court addressed whether an "anonymous telephone caller's question, 'Can I get a 40?' was an implied assertion that the appellant was a seller of cocaine" and whether "it, therefore, fell under the ban of the Rule Against Hearsay." In Garner, the appellant was stopped while driving and arrested for possession of cocaine which was found in his car. Id. at 126. At trial, a police officer testified that "when the appellant's cell phone rang at the station house, he answered it and said, 'Hello.' The caller asked, 'Can I get a 40?' but then hung up when the police officer asked him for his name." Id. The police officer testified that the phone was "ringing non-stop." Id. at 134. A different police officer testified that "the term '40' is a 'common reference' for four-tenths of a gram of crack cocaine." Id. at 126. The appellant "moved in limine to have the content of the call excluded from evidence" as hearsay. Id. at 134. The motion was denied and the State referred to the phone call in its opening statement and closing argument "as proving precisely the thing that it validly served to prove, to wit, that the appellant was a pusher and not a mere user." Id. at 135. As the Garner Court explained, "Although this brief telephone exchange added little, if anything, to the proof of the appellant's guilt as a possessor, it clearly helped to characterize that possession as commercial in nature and not as simple possession for personal use." Id. at 134.