Street v. State

307 Md. 262 (1986)

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Street v. State

Maryland Court of Appeals
307 Md. 262 (1986)

  • Written by Abby Roughton, JD
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Facts

Cab driver George Street (defendant) kept a passenger locked inside his cab for over 25 minutes after the passenger tried to pay a $2.50 cab fare with a $10 bill. The State of Maryland (plaintiff) charged Street with false imprisonment, a common-law crime defined as unlawfully detaining another person against that person’s will. There was no statutorily prescribed penalty for false imprisonment under Maryland law. Street was tried and convicted in a state trial court. After considering the nature of Street’s conduct and Street’s financial condition, the trial judge ultimately sentenced Street to three years of probation plus a $500 fine. The Maryland Court of Special Appeals affirmed the judgment, and the Maryland Court of Appeals reviewed the case to analyze whether the trial court appropriately imposed a fine as part of Street’s sentence.

Rule of Law

Issue

Holding and Reasoning (Cole, J.)

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Casebooks

Criminal Law

Key Terms

  • False ImprisonmentA claim that the defendant detained or restrained the plaintiff in a bounded location without legal authority or the plaintiff’s consent.
  • Common LawLaw that originates from customs and court decisions, rather than from statutes.
  • Cruel and Unusual PunishmentAny criminal sanction that is barbaric, torturous, inhumane, or so disproportionate to the offense committed as to shock the conscience of the community.
  • FineA monetary penalty.

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