Caseflicks

Court of Special Appeals of Maryland • 1994

Williams v. State

646 A.2d 1101 | 101 Md. App. 408 | 1994 Md. App. LEXIS 117

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Takeaway

In short, this case establishes that Maryland’s common-law duress defense is unavailable when a defendant recklessly creates the circumstances making coercion probable, particularly through voluntary involvement in criminal activity.

Background

Marvin Larvae Williams and three other men entered Reverend Chris Glenn Hale’s apartment after Williams knocked on the door and helped gain entry. Three of the men were armed, and one held a gun to Hale’s face while the group demanded money and drugs. Williams told the others that drugs were in the apartment, said he had used drugs there with Hale the day before, and assisted the search. Hale was tied up before the men left; nothing was taken.

Williams testified that the other men had abducted him because they believed he knew the location of a drug stash connected to the Eubanks drug organization. He claimed they threatened to kill him unless he led them to the stash house, so he identified Hale’s apartment and feigned participation in the search. The State’s evidence showed that Williams had voluntarily borrowed money from a member of the organization and had participated in drug runs to repay the debt.

After a bench trial in the Circuit Court for Baltimore County, the court convicted Williams of attempted robbery with a deadly weapon, daytime housebreaking, and use of a handgun in a crime of violence. The court rejected his duress defense, concluding that any coercion concerned repayment of his drug debt rather than an order to rob Hale. Williams appealed, challenging the sufficiency of the evidence and seeking correction of the docket entries.

Issues

Issue #1

Whether Williams could invoke duress when his own prior conduct recklessly placed him in a situation where coercion was probable.

Holding

No. Duress was unavailable because Williams recklessly placed himself in the position in which he was likely to be subjected to coercion.

Reasoning

Maryland’s common-law duress doctrine requires a present, imminent threat of death or serious bodily harm that leaves the defendant no reasonable opportunity to escape. A mere fear, a threat of future harm, or pressure concerning property does not suffice. Earlier Maryland cases also indicated that duress cannot arise from the defendant’s own fault, negligence, or misconduct.

Although Maryland had not enacted a duress statute, the court found persuasive the Model Penal Code, decisions from other jurisdictions, and common-law authorities. Those sources recognize that duress is unavailable when a defendant recklessly places himself in circumstances in which it is probable that he will later face coercion. Recklessness means consciously disregarding a substantial and unjustifiable risk.

The court adopted that rule for Maryland: a defendant who recklessly places himself or herself in a situation where duress is probable may not use duress as a defense. The rule is especially applicable to persons who voluntarily connect themselves with criminal activity, even though it can result in liability for an intentional offense when the defendant’s responsibility for entering the coercive situation was only reckless.

Williams voluntarily became involved with the Eubanks drug organization, borrowed money from Rodney Eubanks, and participated in drug runs to repay the debt. That involvement made his connection to the organization known to the men who later abducted him and created the very predicament from which his claimed coercion arose. Because his own reckless conduct contributed substantially to that danger, the trial court properly rejected duress.

Issue #2

Whether the evidence was sufficient to support Williams’s conviction for attempted robbery with a deadly weapon.

Holding

Yes. The evidence supported a finding that Williams aided and encouraged an attempted robbery as a principal in the second degree.

Reasoning

Attempt liability in Maryland requires a substantial step toward the intended offense that strongly corroborates criminal intent. Robbery is larceny from the person accomplished by violence or intimidation, and a person who aids, counsels, commands, or encourages a felony in the perpetrator’s presence may be guilty as a principal in the second degree.

Williams directed the group to Hale’s apartment, helped the men enter, told them that drugs were there, and participated in searching the apartment. His fingerprints on two drawers corroborated Hale’s account that Williams assisted in ransacking the residence.

Even if Williams personally did not expect to find drugs or money in Hale’s apartment, the evidence permitted the trial court to find that he knew the other men intended to steal and that he knowingly assisted their effort. Their armed entry, demands for money and drugs, and search of the apartment were substantial steps toward robbery. The trial court’s verdict was therefore not clearly erroneous.

Issue #3

Whether the docket entries should be corrected to identify the attempted-robbery conviction accurately.

Holding

Yes. The docket entries were ordered corrected to reflect a conviction for attempted armed robbery.

Reasoning

The State agreed that the docket entries did not accurately describe Williams’s conviction. The appellate court therefore affirmed the judgments while directing correction of the entries to reflect attempted armed robbery.