Oates v. State

Maryland Court of Special Appeals

627 A.2d 555 (Md. Ct. Spec. App. 1993)

Despite each defendant having acted with a different mindset, multiple defendants may still be found guilty of the same criminal act.

Relevant Facts

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

Issue

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Holding & Reasoning

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Concurrence

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Dissent

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Last updated:

December 23, 2020

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Procedural History

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Citations

627 A.2d 555 (Md. Ct. Spec. App. 1993)