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Oates v. State

Maryland Court of Special Appeals
627 A.2d 555 (1993)


Facts

Robert Louis Oates, III and Roderick Giles (defendants) attacked Patrick Stanford, who was fatally stabbed during the ensuing brawl. The State of Maryland (plaintiff) prosecuted Oates and Giles for criminal homicide and presented sufficient trial evidence to support the jury's findings and conclusions. The jury found that Giles was a principal in the first degree because he struck the fatal blow and acted with the specific but unpremeditated intent to kill Stanford. The jury convicted Giles of second-degree murder. The jury found that Oates was a principal in the second degree because he actively aided and abetted Giles during the brawl. The jury did not find that Oates acted with the specific intent to kill Stanford or inflict grievous bodily harm. Instead, the jury found that Oates either did not care if Stanford was killed, or intended only that Stanford suffer nonfatal injuries. The jury convicted Oates of involuntary manslaughter. Oates appealed his conviction to the Maryland Court of Special Appeals, contending that it was legally inconsistent to find Oates guilty of involuntary manslaughter for aiding and abetting Giles in the commission of second-degree murder.

Rule of Law

Issue

Holding and Reasoning (Moylan, J.)

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