Md. high court upholds teen’s murder conviction in Baltimore County officer’s death

A unanimous Maryland high court has upheld the first-degree felony murder conviction and life sentence of a 16-year-old who accelerated a stolen sports utility vehicle and ran into and killed a Baltimore County police officer who had told him to stop.

In its 7-0 decision Wednesday, the Court of Appeals rejected Dawnta Harris’ argument through counsel that his conviction for killing officer Amy Caprio on May 21, 2018, must be overturned because unintended killings by motor vehicle cannot be the basis of a murder conviction under Maryland law.

The court agreed that Maryland’s “manslaughter by vehicle” statute governs unintended homicides but said felony murder is legally regarded as an intentional killing not covered by the vehicle law. Under the felony murder doctrine, Harris’ intention to commit the underlying felony – in this case first-degree burglary – was essentially “transferred” to an intent to commit the killing that followed, the court said.

“Treating a killing that occurs during the course of a felony in the same way as first-degree murder is rooted in the judgment that the intent to perpetrate a felony that results in a death is as worthy of blame and punishment as a specific intent to kill,” Judge Michele D. Hotten wrote for the Court of Appeals. “Petitioner (Harris) has failed to offer any compelling rationale for why a killing perpetrated by a motor vehicle in furtherance of a felony should be treated differently than all other felonies, simply because it was perpetrated by a motor vehicle.”

The Court of Appeals also rejected Harris’ contention that his sentence of life in prison with the possibility of parole violates the Maryland Constitution’s prohibition on “cruel or unusual” punishment for minors.

The high court said the Maryland’s ban affords convicts no greater protection than the federal Constitution’s prohibition on “cruel and unusual” punishment.

In interpreting the federal Constitution, the U.S. Supreme Court has held that heightened judicial scrutiny before minors are sentenced to life in prison without parole does not apply to youngsters, such as Harris, who are sentenced to life in prison with the possibility of parole, the Court of Appeals said.

Nevertheless, the court added, Baltimore County Circuit Judge Jan Marshall Alexander engaged in the heightened scrutiny by considering Harris’ youth and “attendant circumstances,” such as impetuosity, lack of judgment and susceptibility to peer pressure, before handing down the valid sentence of life in prison with the possibility of parole.

“It is evident that petitioner’s case does not reflect gross disproportionality warranting a determination that his life sentence was unconstitutional as applied,” Hotten wrote. “Petitioner’s conduct was extremely serious: he committed a felony during which he caused the loss of human life.”

Harris’ appellate attorney, Megan E. Coleman, stated via email Thursday that the court’s ruling should send a message to reform-minded state legislators.

“While we are disappointed in the court’s decision, we hope that these arguments shed light on evolving areas of the law that may be further addressed by the General Assembly to achieve more equitable sentencing proceedings for juvenile offenders,” stated Coleman, of MarcusBonsib LLC in Greenbelt. “Specifically, the appeal provided a framework for the General Assembly to formulate precise sentencing factors as it relates to youth and the attendant circumstances before imposing a life sentence on a juvenile offender.”

The Maryland attorney general’s office declined to comment on the high court’s decision.

At Harris’ 2019 trial, Baltimore County Circuit Court jurors heard that he and several accomplices had burglarized a Baltimore man’s home on May 18, 2018, and stolen his Jeep Wrangler. The jury also watched Caprio’s body-worn camera footage taken three days later.

According to the Associated Press, Caprio could be heard repeatedly ordering Harris out of the car before the 29-year-old officer drew her gun and screamed “Stop! Stop!”

Harris ducked his head, hit the gas and the Jeep slammed into Caprio. She fired once, the bullet shattering the windshield. Harris ditched the stolen car a few blocks away.

The intermediate Court of Special Appeals upheld Harris’ conviction and sentence last July, prompting his appeal to the high court.

Harris’ three accomplices pleaded guilty to first-degree felony murder and were each sentenced to life in prison with all but 30 years suspended. They are Darrell J. Ward, Derrick E. Matthews and Eugene R. Genius IV.

The Court of Appeals rendered its decision in Dawnta Harris v. State of Maryland, No.  45, September Term 2021.