Law School Case Brief
Street v. State - 307 Md. 262, 513 A.2d 870 (1986)
The only restrictions on sentencing for a common-law crime are (absent a penalty prescribed by statute) is that the sentence be within the reasonable discretion of the trial judge and that it not be cruel and unusual punishment.
Valerie McNeal, the victim, was the passenger in a taxi cab driven by defendant George Street. When the cab reached McNeal's destination, the meter read $2.50. McNeal had $2.46 in change, plus one $10 and one $20 bill. Street did not have enough money to make exact change, so re refused to accept the $10 bill; he also rejected McNeal's suggestion that they obtain change for the $10 bill at a nearby establishment. When McNeal attempted to get out of the cab, she found that the rear doors were locked. Despite McNeal's repeated requests, Street refused to disengage the locks, which he controlled. The parties argued for approximately 25 minutes, with the meter running all the while. Ultimately, a passerby came to McNeal's aid and persuaded Street to accept the $10 bill in payment of the fare, which had risen to $5.20. Street gave the passerby a $5 bill, which she promptly turned over to McNeal. Shortly thereafter, a police officer arrived on the scene, and Street finally released McNeal from the cab. Later, after a trial in Maryland state court, Street was convicted of false imprisonment, and he was sentenced to one-year imprisonment and a $500 fine, with the prison term suspended in favor of three years' probation. The court of special appeals affirmed the judgment. Street was granted a writ of certiorari in which he challenged the imposition of the fine.
Was it error to impose a fine against Street as a part of his sentence on his conviction for the common-law crime of false imprisonment?
Court of Appeals of Maryland affirmed the judgment of the court of special appeals and ordered Street to pay the costs of appeal. The court observed that false imprisonment was a common-law crime and that misdemeanors at common law were punishable by fine, imprisonment, or both. The court further noted that it was its usual practice to refuse to limit sentences for common-law offenses where the legislature had not expressly so provided. The only restriction on sentencing for a common-law crime, in the absence of a penalty prescribed by statute, was that the sentence be within the reasonable discretion of the trial judge and that it not be cruel and unusual punishment. In Street's case, the court noted that the trial judge examined the Street's conduct and considered Street's financial condition with regard to his ability to pay the fine. Taking all of these into consideration, the court concluded that the imposition of the fine constituted a reasonable exercise of the judge's discretion and did not constitute cruel and unusual punishment.
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