defense-of-others instruction (Maryland) · Go Syfert
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defense-of-others instruction in Maryland

5 Maryland opinions name it 2 courts 2010–2026 2 in the last five years

The cases below were cited by Maryland courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (5)

CaseFollowedCited
Lee v. Stategreen
mdctspecapp · 2010 · cited in 2 Maryland opinions naming this issue, 2025–2026
2 sentences

2026See, e.g., Danshin, 491 Md. at 541-50 (analyzing whether some evidence as to each element of the defense of others defense was adduced using both self-defense and defense of others cases as guidance); Lee, 193 Md.

2026See, e.g., Danshin, 491 Md. at 541-50 (analyzing whether some evidence as to each element of the defense of others defense was adduced using both self-defense and defense of others cases as guidance); Lee, 193 Md.

22
Belton & Worsley v. Stategreen
mdctspecapp · 2021 · cited in 1 Maryland opinions naming this issue, 2026–2026
1 sentence

2026Indeed, the trial court extensively discussed Belton v. State for the proposition that: if two are engaged unlawfully in a mutual fight (deadly or nondeadly) the law does not authorize anyone (close relative or stranger) to take sides in the contest and aid in the effort to overcome his adversary . . . [o]bviously, the law does not authorize anyone to join forces with the offender and aid in harming the innocent victim. 253 Md.

11
Sims v. Stategreen
md · 1990 · cited in 1 Maryland opinions naming this issue, 2025–2025
1 sentence

2025First, Mr. Danshin contends that a defendant may receive the instruction even when they simultaneously deny being the shooter, i.e., that a defendant may put forth inconsistent defenses, claiming support from our holding in Sims v. State, 319 Md. 540, 550 (1990).

11
Mora v. Stategreen
md · 1999 · cited in 1 Maryland opinions naming this issue, 2014–2014
2 sentences

2014See, e.g., Black v. State, 426 Md. 328, 337 , 44 A.3d 362 (2012) (“Appellant or petitioner has the burden of producing a sufficient factual record for the appellate court to determine whether error was committed.”); Mora v. State, 355 Md. 639, 649-50 , 735 A.2d 1122 (1999) (“It is incumbent upon the appellant claiming error to produce a sufficient factual record for the appellate court to determine whether error was committed.”).

2014See, e.g., Black v. State, 426 Md. 328, 337 , 44 A.3d 362 (2012) (“Appellant or petitioner has the burden of producing a sufficient factual record for the appellate court to determine whether error was committed.”); Mora v. State, 355 Md. 639, 649-50 , 735 A.2d 1122 (1999) (“It is incumbent upon the appellant claiming error to produce a sufficient factual record for the appellate court to determine whether error was committed.”).

11
Black v. Stategreen
md · 2012 · cited in 1 Maryland opinions naming this issue, 2014–2014
2 sentences

2014See, e.g., Black v. State, 426 Md. 328, 337 , 44 A.3d 362 (2012) (“Appellant or petitioner has the burden of producing a sufficient factual record for the appellate court to determine whether error was committed.”); Mora v. State, 355 Md. 639, 649-50 , 735 A.2d 1122 (1999) (“It is incumbent upon the appellant claiming error to produce a sufficient factual record for the appellate court to determine whether error was committed.”).

2014See, e.g., Black v. State, 426 Md. 328, 337 , 44 A.3d 362 (2012) (“Appellant or petitioner has the burden of producing a sufficient factual record for the appellate court to determine whether error was committed.”); Mora v. State, 355 Md. 639, 649-50 , 735 A.2d 1122 (1999) (“It is incumbent upon the appellant claiming error to produce a sufficient factual record for the appellate court to determine whether error was committed.”).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Maryland. Read the followed side critically anyway.

Also cited on this issue (3)

CaseCitedYears
Jarvis v. State green
md · 2024
1 sentence

2025Id.

12025–2025
Tucker v. State green
md · 2009
2 sentences

2012Tucker v. State, 407 Md. 368, 379 , 965 A.2d 900 (2009).

2012Tucker v. State, 407 Md. 368, 379 , 965 A.2d 900 (2009).

12012–2012
Guerriero v. State green
md · 1957
2 sentences

2010In Guerriero v. State, 213 Md. 545 , 132 A.2d 466 (1957), the Court of Appeals considered whether the trial judge, sitting as the trier of fact, erred in finding a defendant guilty of assault, rejecting a defense of others defense.

2010In Guerriero v. State, 213 Md. 545 , 132 A.2d 466 (1957), the Court of Appeals considered whether the trial judge, sitting as the trier of fact, erred in finding a defendant guilty of assault, rejecting a defense of others defense.

12010–2010

Where else courts name it

MI 13 (2002–2025) OH 10 (2004–2026) WI 7 (1988–2025) MO 6 (2013–2025) MS 6 (2007–2018) CT 5 (2011–2020) MD 5 (2010–2026) CA 4 (2013–2025) UT 3 (2011–2026) KS 3 (1997–2024) OR 2 (2005–2023) WA 2 (2011–2020) MN 2 (2023–2024) VA 2 (2001–2010) HI 2 (2019–2021) IL 2 (2016–2016) NC 2 (2022–2022) CO 2 (2025–2026)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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