State v. Thomas
464 Md. 133, 211 A.3d 274 (2019)
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Rule of Law:
The act of distributing heroin can constitute gross negligence involuntary manslaughter when the totality of the circumstances, including the inherent dangerousness of the drug and other environmental risk factors, demonstrates the seller's wanton and reckless disregard for human life.
Facts:
- Patrick Joseph Thomas was a regular user and dealer of heroin, who resupplied his stock every few days.
- Colton Lee Matrey, a 23-year-old with a four-and-a-half-year history of heroin addiction, had recently moved to Maryland in an attempt to get clean.
- On the night of June 25, 2015, Matrey frantically called Thomas 27 times and sent multiple desperate text messages between 11:45 p.m. and 12:07 a.m. seeking to buy heroin.
- Around midnight, Thomas met Matrey and sold him four bags of heroin stamped with the name "Banshee."
- Later that night, Matrey's mother found him unresponsive in a locked bathroom; he was pronounced dead at the scene.
- Police found one empty "Banshee" heroin bag in Matrey's hand and three identical empty bags on the floor, along with a syringe in his pocket.
- An autopsy determined Matrey's cause of death was 'alcohol and narcotic (free morphine) intoxication.'
- Thomas later admitted to police that he sold Matrey the four bags but expressed surprise that this amount could cause an overdose, noting that he himself used four bags in a single shot.
Procedural Posture:
- The State charged Patrick Joseph Thomas in the Circuit Court for Worcester County (trial court) with distribution of heroin, reckless endangerment, and involuntary manslaughter.
- Thomas proceeded on an agreed statement of facts in a 'hybrid plea.'
- The trial court found Thomas guilty on all counts, including involuntary manslaughter.
- Thomas, as appellant, appealed his involuntary manslaughter conviction to the Court of Special Appeals of Maryland (intermediate appellate court).
- The Court of Special Appeals reversed the conviction, holding the evidence was insufficient to establish either gross negligence or the necessary causation.
- The State, as appellant, petitioned for a writ of certiorari to the Court of Appeals of Maryland (the state's highest court) to review the reversal of the gross negligence involuntary manslaughter conviction, which the court granted.
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Issue:
Is the evidence sufficient to convict a heroin dealer of gross negligence involuntary manslaughter when he sells heroin to a person who subsequently dies from a self-administered overdose?
Opinions:
Majority - Adkins, J.
Yes. The evidence was sufficient to convict Thomas of gross negligence involuntary manslaughter. To determine if conduct is grossly negligent, courts must assess whether it was 'likely at any moment to bring harm to another' by weighing the inherent dangerousness of the act with environmental risk factors. The court found that the consumption of heroin of unknown strength is inherently dangerous. This inherent danger was compounded by several risk factors: the community was experiencing a heroin epidemic, Thomas knew Matrey was a 'young boy,' and Matrey's frantic calls and texts demonstrated a desperation that made immediate consumption of all four bags foreseeable. Thomas, as an experienced user and dealer, was or should have been aware of these risks, and his failure to mitigate them showed an indifference to the consequences, constituting a wanton and reckless disregard for human life. The victim's self-injection does not break the causal chain because it is a foreseeable consequence of the sale, and contributory negligence is not a defense to involuntary manslaughter.
Dissenting - Hotten, J.
No. The evidence is not sufficient to establish the required causal relationship between the mere sale of heroin and the buyer's subsequent fatal overdose. The causal chain was broken because Thomas's actions and Matrey's death were not part of a 'continuous transaction.' Thomas was not present when Matrey injected the heroin, was unaware of other substances Matrey ingested, and did not prepare the dose or assist in the injection. Furthermore, the legislature has repeatedly declined to pass laws that would specifically criminalize drug distribution resulting in death, and the court should not create such a crime through judicial interpretation, as it is a policy matter best left to the General Assembly.
Analysis:
This case establishes a significant precedent in Maryland, holding that a drug dealer can be convicted of homicide for a customer's overdose death under a gross negligence theory. The ruling broadens the scope of criminal liability by focusing on the totality of circumstances rather than requiring the dealer's direct participation in the drug's administration. It signals that in the context of a public health crisis like the opioid epidemic, the act of selling a dangerous drug carries a heightened level of foreseeable risk. This decision will likely encourage prosecutors to pursue manslaughter charges in overdose cases, potentially impacting how drug-related deaths are investigated and prosecuted statewide.
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