Ford v. State
Court of Appeals of Maryland
625 A.2d 984 (1993)
Maurice Ford (defendant) and others threw large rocks at passing vehicles from a highway overpass, injuring numerous drivers and passengers and damaging property; he was charged in a 90-count indictment including multiple counts of assault with intent to disable covering both drivers and vehicle passengers. At trial, the judge instructed the jury it could transfer Ford's intent to disable the drivers to the vehicles' passengers as well, and Ford did not object; he was convicted on 52 counts, and the court of special appeals reversed two property-destruction counts but affirmed the rest, concluding the transferred-intent doctrine was actually inapplicable to these crimes; the Maryland Court of Appeals granted certiorari.
Whether the doctrine of transferred intent is inapplicable if the subject crime is already completed as to an intended victim.