Oates v. State

627 A.2d 555 (1993)

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Nature of the Case

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Facts

A birthday celebration was held at the Classics III Restaurant. Neither D nor the codefendant, Giles, were participants in that celebration but they were present at the restaurant. A fight broke out between D and Giles, on the one hand, and various party guests, on the other hand. Still within the restaurant, one of the party guests and the ultimate homicide victim, Patrick Stanford, was involved in the fight and either D or Giles punched Stanford in the mouth, knocking out four teeth. D and Giles then moved on to other fights with other party guests. D and Giles left the restaurant and were on the parking lot at the same time that various party guests, including Stanford, were leaving. Threats were hurled between the two opposing camps. A witness described how Giles grabbed from his car and then waved menacingly a 'butterfly knife.' Stanford drove away from the scene in a station wagon with two female companions. D and Giles left the scene in Giles's white Jetta. Shortly thereafter, the station wagon was stopped for a traffic light when the Jetta pulled up behind it. D and Giles got out of the Jetta and, with a crowbar, smashed the windows of the station wagon. Stanford was pulled out of the wagon and both assailants proceeded to punch and kick him. Pattina Avery, in whose honor, incidentally, the birthday party had been held, testified that both assailants were 'punching and stabbing' Stanford at the same time. A University of Maryland student who was simply driving in the area testified that one of the assailants was holding the victim while the other was hitting him. After the victim fell to the ground, the two attackers proceeded to kick him. The medical examiner testified that Stanford's body revealed facial injuries, broken teeth, and twelve stab wounds. The cause of death was the multiple stab wounds. Giles and admitted their participation in the final altercation with Patrick Stanford at the traffic light. Giles handed D a crowbar and D jumped out and 'began busting out the windows of the car.' As the two female passengers ran screaming from the scene, Stanford got out of the car and allegedly attacked Giles with a knife. According to Giles, he and D overpowered Stanford and took the knife away. Giles then described how he began 'throwing punches' at Stanford with the knife in his hand but denied any actual stabbing. He testified that D was also punching Stanford, although without a knife. Giles was later shocked to learn that the victim had been stabbed. D acknowledged getting out of the car at the traffic light and smashing out the back window of the car. D was surprised when Giles began fighting with the victim and D tried to pull Giles off the victim. D disclaimed any intention of hurting anyone that evening. The jury concluded that Giles was a principal in the first degree, the wielder of the weapon that struck the fatal blows. The jury concluded that Giles attacked Stanford with a specific intent to kill. The jury gave Giles the benefit of the doubt, however, when it concluded that that specific intent to kill was not premeditated. The obvious verdict under the circumstances was that Giles was guilty of murder in the second degree. The jury concluded that D jointly participated with Giles in the criminal homicide. The jury concluded that D was a principal in the second degree, not wielding the lethal weapon but actively aiding and abetting the man who did. The jury did not conclude that D attacked Stanford with a specific intent to kill or even a specific intent to do grievous bodily harm. It found that D was guilty of either 1) grossly negligent, life-endangering conduct toward Stanford or 2) the perpetration of an unlawful act (assault and battery) upon Stanford that resulted in Stanford's death. D was found guilty of involuntary manslaughter.

D appealed.