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RICHARD BROOKS v. STATE OF MARYLAND

Criminal procedure — Jury instructions — Aiding and abetting

Richard Brooks and Mark Hatmaker were involved in a conspiracy to illegally purchase prescription pharmaceuticals. The day after their drug deal fell through, Hatmaker disappeared. While Hatmaker’s body was never found, his blood was found on two motor vehicles: on the bumper of a U-Haul truck rented for Brooks in Anne Arundel County, and in Brooks’s recreational vehicle (“RV”), which was parked in Anne Arundel County and later moved to Baltimore City. Brooks was charged and convicted in the Circuit Court for Anne Arundel County for Hatmaker’s murder.

On appeal, Brooks presents three questions: 1. Did the motions court err in ruling that venue was proper in Anne Arundel County? 2. Did the trial court commit reversible error by allowing the State to comment on Brooks’s silence during the rebuttal closing? 3. Did the trial court commit reversible error by instructing the jury on a theory of guilt by aiding and abetting?

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