Harris v. State case brief

Harris v. State case brief summary
728 A.2d 180 (1999)

CASE SYNOPSIS

Defendant appealed from a decision of the Circuit Court for Prince George's County (Maryland), convicting him of the offense of carjacking. Defendant based his appeal on the contention that the trial court erred in instructing the jury that carjacking was not a specific-intent crime.

CASE FACTS
Defendant was convicted of carjacking. At his trial, defendant insisted that he had consumed alcohol and smoked marijuana on the evening of the crime and that he blacked out and could not remember committing the crime. The trial court instructed the jury that carjacking was not a specific-intent crime, thereby negating defendant's defense of voluntary intoxication.

DISCUSSION

• On appeal, the court held that the trial court did not err in its instructions to the jury regarding intent. The court held that the carjacking statute, viewed as a whole, did not demonstrate an intent on the part of the legislature to create a specific intent crime, because words such as "with intent to" were conspicuously absent from the statute. 
• The court stated that where a statute did not contain any reference to intent, general intent should be implied. 
• Therefore, defendant's conviction was affirmed and the court held that the trial court did not err when it instructed the jury that carjacking was not a specific-intent crime.

CONCLUSION
Defendant was not granted relief on appeal and the court affirmed defendant's conviction for carjacking. The court held that the trial court did not err in instructing the jury that carjacking was not a specific-intent crime, because the statute itself used no words indicating intent as an element of the crime.

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