Campbell v. State

293 Md. 438 (1982)

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Campbell v. State

Maryland Court of Appeals
293 Md. 438 (1982)

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  • Written by Kelli Lanski, JD

Facts

Anthony Campbell (defendant) and another man (the co-felon) got into a cab one evening and instructed the driver to take them to a street full of deserted buildings. The co-felon then took out a gun and ordered the taxi driver to give them all his money. Campbell told the driver to do as his co-felon asked, saying he also had a gun. After the taxi driver complied with their request, Campbell’s co-felon instructed the driver to drive to a new location so they could kill him because he had seen their faces. As the driver complied, he saw a couple of police cars in the road ahead. He hit the brakes alongside one police car, at which time Campbell’s co-felon opened fire on the taxi driver. The driver returned fire with his own gun, and both the co-felon and the driver were wounded. Police officers came to the driver’s assistance, shooting at Campbell and his co-felon, both of whom left the taxi and ran. Campbell hid in a nearby vestibule, but his co-felon was pursued by police officers and shot several more times. Campbell’s co-felon died from bullet wounds, although the autopsy could not determine whether shots by police or the taxi driver had killed him. Campbell was arrested and pled guilty to first-degree felony murder of a co-felon, among other charges. The trial court accepted Campbell’s plea and convicted him. Campbell later appealed his first-degree-murder conviction.

Rule of Law

Issue

Holding and Reasoning (Davidson, J.)

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Casebooks

Criminal Law

Key Terms

  • FelonyA serious crime, usually defined as a crime punishable by imprisonment of more than one year or a sentence of death.
  • First-Degree MurderThe killing of another with malice aforethought and, in most jurisdictions, with premeditation and deliberation or other aggravating elements.
  • Guilty PleaA defendant’s official confession to the crime and waiver of the right to trial by jury.
  • Agency Theory of Felony MurderTheory holding a defendant criminally liable only for deaths that are caused by the defendant or an accomplice during and in furtherance of the commission or attempted commission of a felony.

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