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Williams v. State

Court of Appeals of Maryland
561 A.2d 216 (1989)


Williams (defendant) and Jones were arguing over a photo that depicted Jones’ girlfriend acting unfaithfully with Williams. Jones grabbed Williams’s wallet and ran, trying to get the picture. Williams went inside his house and called the police. When Williams returned outside, Jones attempted to attack him, swinging a lead pipe numerous times. Williams went back inside and obtained a bow and arrow, with which he pursued Jones. Right before he released an arrow meant for Jones, Williams yelled a warning to Jewel Lyles, who was walking by, to “watch out.” The arrow hit Lyles, and she died from the wound. At the time of the shooting, Lyles was nine months pregnant. The baby was born alive prior to Lyles’s death, but died shortly after as a result of the mother’s injury. Williams was convicted by a jury of manslaughter for the deaths of both Lyles and her baby. Williams appealed. Because Maryland law required the court to apply the English common law, the court mainly considered the views of two prominent English commentators, Lord Hale and Lord Coke. Hale understood the common law to say that if a baby was born alive and subsequently died of injuries criminally inflicted upon the pregnant mother, the situation did not constitute murder or manslaughter. In contrast, Coke’s view was that such circumstances did amount to a criminal homicide. After noting that a number of American jurisdictions accepted Coke’s view, the court concluded that the English common law supported Coke’s born-alive rule. The court held that it is the common law of Maryland that when a child is born alive, but subsequently dies as a result of injury sustained in utero, the death of the child is a homicide. Williams appealed, arguing that the version of the common law accepted by the court should not be applied to his manslaughter conviction.

Rule of Law


Holding and Reasoning (Murphy, J.)

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