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State v. Thomas

Maryland Court of Appeals

211 A.3d 274 (2019)

Facts

Patrick Thomas (defendant) sold and used heroin. One night, Colton Matrey sought to purchase heroin from Thomas. Matrey called Thomas 27 times and sent numerous messages. Eventually, the men connected, and Thomas sold Matrey four bags of heroin. Soon after, Matrey died of a heroin overdose. Police found communications between Thomas and Matrey on Matrey’s phone and arrested Thomas. Thomas admitted selling heroin to Matrey, but Thomas asserted that Matrey could not have overdosed on the amount that Thomas had sold to Matrey. Thomas was tried and convicted of gross-negligence involuntary manslaughter. Thomas successfully appealed based on sufficiency of the evidence. The State of Maryland (plaintiff) appealed to the Maryland Court of Appeals.

Rule of Law

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Issue

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Holding and Reasoning (Adkins, J.)

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Dissent (Hotten, J.)

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