Alexander v. State
52 Md. App. 171, 1982 Md. App. LEXIS 318, 447 A.2d 880 (1982)
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Rule of Law:
Under Maryland law, the defense of others is not contingent on the person being defended having an actual right to self-defense. Instead, an intervenor's use of force is justified if it is based on the intervenor's own reasonable belief that another person is the victim of a violent assault.
Facts:
- Correctional officers Dale Tscheulin and Samuel Stokes, Jr., were involved in a physical altercation with an inmate, Bruce Shreeves, on a catwalk inside the Maryland Penitentiary.
- Ralph Alexander, another inmate, witnessed a portion of the altercation.
- Alexander testified that he saw the officers beating Shreeves and believed Shreeves was the victim of an unprovoked, violent assault.
- The officers testified that Shreeves was the initial aggressor and they were attempting to lawfully subdue him when Alexander intervened.
- Alexander approached Officer Tscheulin, who was engaged with Shreeves, and became physically involved in the altercation.
- Alexander stated he only pinned Officer Tscheulin against the bars to stop the perceived beating.
- The officers stated that Alexander leapt on Officer Tscheulin and struck him in the chest and head.
Procedural Posture:
- Ralph Alexander was prosecuted for assault on a correctional officer in the Criminal Court of Baltimore.
- At trial, the judge instructed the jury that Alexander's right to defend fellow inmate Bruce Shreeves was identical to Shreeves' own right to self-defense, meaning Alexander 'stands in the same shoes as Shreeves.'
- Alexander's defense counsel made a timely objection to this jury instruction, arguing that Alexander's actions should be judged based on what he saw.
- The jury convicted Alexander of assault.
- Alexander appealed his conviction to the Court of Special Appeals of Maryland, challenging the trial court's jury instruction.
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Issue:
Does Maryland's 'defense of others' statute require that the person being aided was actually entitled to use self-defense, or is the intervenor's conduct judged based on the reasonable appearance of the situation to the intervenor?
Opinions:
Majority - Lowe, J.
No, the intervenor's conduct is judged based on the reasonable appearance of the situation to the intervenor. The trial court erred by instructing the jury that the defendant's right to defend another was strictly tied to the other person's actual right to self-defense. At common law, an intervenor acted at their peril, 'standing in the shoes' of the person they aided. However, in 1965, the Maryland legislature enacted a 'Good Samaritan' statute (Art. 27, § 12A) intended to encourage bystanders to aid apparent victims of violent assaults. The statute's focus on a person 'witnessing a violent assault' indicates that the justification for intervention rests on the intervenor's own reasonable perceptions, not the objective reality of the situation or the fault of the person being aided. To interpret the statute as merely codifying the restrictive common law rule would render it purposeless. Therefore, Alexander must be judged on his own conduct and his reasonable observations of the circumstances, not on whether Shreeves was actually entitled to self-defense.
Analysis:
This decision officially departs from the common law 'alter ego' rule (standing in the shoes of another) for the defense of others in Maryland, adopting the more modern 'reasonable belief' standard. By interpreting the state's 'Good Samaritan' statute, the court aligns Maryland with a legal trend that encourages bystander intervention by protecting individuals who act on a reasonable, albeit mistaken, belief that someone is being unlawfully assaulted. This precedent lowers the legal risk for individuals who choose to 'get involved' and shifts the jury's focus from the aided person's culpability to the intervenor's state of mind and the reasonableness of their perceptions and actions.
