State v. Minster

486 A.2d 1197 (1985)

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State v. Minster

Maryland Court of Appeals
486 A.2d 1197 (1985)

Facts

Larry Minster (defendant) shot Cheryl Dodgson in the neck, causing her to become a quadriplegic. Minster was convicted of attempted first-degree murder and sentenced to 20 years in prison. Six months after Minster’s trial and one year and 87 days after Minster shot Dodgson, Dodgson died. The State of Maryland (plaintiff) claimed that Dodgson’s death was a direct result of being shot by Minster and formally charged him with murdering Dodgson. However, the trial court dismissed the charge, applying a common-law rule that a defendant did not cause someone’s death if the person died more than one year and one day after being injured by the defendant. The state appealed, arguing that the common-law rule should be abolished because it was outdated in light of current medical capabilities. In response, Minster argued that (1) the rule still provided value and (2) the legislature, not the courts, should be the body to make any changes to the rule.

Rule of Law

Issue

Holding and Reasoning (Couch, J.)

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