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SAMUEL WILLIAMS v. STATE OF MARYLAND

Criminal procedure — Jury instruction — Accomplice liability

After a five day jury trial in the Circuit Court for Montgomery County, the Honorable David A. Boynton presiding, Samuel Williams was convicted of attempted second-degree murder and first-degree assault. Mr. Williams presents the following issues, which we have reworded: 1. Did the hearing court interfere with Williams’s right to due process and a fair trial by inducing a co-defendant to invoke his Fifth Amendment privilege to not testify at Williams’s trial? Did the trial court err in refusing to admit the hearsay statement of the co-defendant as a statement against penal interest exception? 3. Did the trial court err in providing the jury with the comment to the model jury instruction, in response to a jury question on accomplice liability?

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