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Criminal Law Keyed to Gershowitz
Oates v. State
Citation:
97 Md.App. 180, 627 A.2d 555.Facts
On April 14th, 1990, a birthday party was being held at a restaurant. The defendant and co-defendant, Roderick Giles, were not participating in the party, but were also at the restaurant. A fight broke out between the defendant and the codefendant, on the one hand, and various party guests, including Patrick Stanford, on the other hand.
At some point, the defendant and Giles left the restaurant and were on the parking lot at the same time that various party guests were leaving. The defendant and Giles then saw Patrick Stanford at a stoplight. They got out of their car with a crowbar and smashed the windows of Stanford’s vehicle. Stanford was pulled out of the vehicle and both defendants proceeded to punch and kick him. The co-defendant also stabbed him. Stanford did not survive.
The defendant testified that it was his intention only to break the window and then leave. He was surprised when Giles began fighting with the victim and he tried to pull Giles off the victim. He disclaimed any intention of hurting anyone that evening. The jury found that the defendant jointly participated with Giles in the criminal homicide. The jury convicted Giles of second-degree murder and Oates of involuntary manslaughter. He appealed, arguing that his guilty verdict was legally inconsistent as he couldn’t have aided and abetted a manslaughter when the person he aided and abetted was not found guilty of manslaughter.
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