Williams v. State
646 A.2d 1101, 101 Md. App. 408, 1994 Md. App. LEXIS 117 (1994)
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Rule of Law:
The common law defense of duress is unavailable if the defendant recklessly placed themself in a situation in which it was probable that they would be subjected to coercion.
Facts:
- Marvin Larvae Williams borrowed money from Rodney Eubanks, the brother of a reputed drug dealer, Chuckie Eubanks.
- To repay his debt, Williams voluntarily became involved with the Eubanks' drug organization and made drug runs to New York.
- During one drug run, Williams cooperated with the police, providing them with information about the drug organization.
- Three men, who were former members of the Eubanks organization, later abducted Williams because they believed he knew the location of a drug stash house.
- The abductors threatened to kill Williams if he did not disclose the location of the stash house.
- To save himself, Williams led the men to the apartment of an innocent person, Reverend Chris Glenn Hale, falsely claiming it was the stash house.
- Williams knocked on the door, and when Hale partially opened it, the four men, including Williams, rushed inside.
- Once inside, one of the men held a gun to Hale's face while Williams pretended to participate in the search for drugs and money.
Procedural Posture:
- Marvin Larvae Williams was charged with attempted robbery with a deadly weapon, daytime housebreaking, and use of a handgun in the Circuit Court for Baltimore County, a state trial court.
- Williams waived his right to a jury trial, proceeding with a bench trial.
- At the conclusion of the trial, the judge requested legal memoranda from the parties regarding the defense of duress.
- The trial court judge found Williams guilty of all charged offenses.
- Williams, as appellant, filed a timely appeal of his conviction to the Court of Special Appeals of Maryland, an intermediate appellate court.
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Issue:
Is the defense of duress available to a defendant who, through their own reckless conduct by associating with a criminal enterprise, placed themselves in a situation in which it was probable that they would be subjected to duress?
Opinions:
Majority - Alpert, J.
No. The defense of duress is unavailable where a defendant recklessly places themself in a situation where it is probable that they would be subjected to duress. The court adopts the Model Penal Code § 2.09(2) standard, which holds that the defense is forfeited by a defendant's own recklessness. By voluntarily associating with a drug organization to repay a debt, Williams engaged in reckless conduct that made it probable he would be subjected to coercion by other members of the criminal underworld. The duress he faced was a direct result of his own fault in connecting himself with criminal activities, and therefore the defense is inapplicable.
Analysis:
This decision formally incorporates the Model Penal Code's limitation on the duress defense into Maryland's common law. It establishes a clear precedent that defendants cannot claim duress if their own prior reckless actions, particularly voluntary involvement in a criminal enterprise, led to the coercive situation. This ruling aligns Maryland with the majority of jurisdictions and provides a standard that prevents defendants from using their own fault as a shield against criminal liability. Future cases involving duress will now require courts to analyze whether the defendant's own conduct contributed to the circumstances giving rise to the coercion.
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