Purnell v. State

252 A.3d 94, 250 Md. App. 703
CourtCourt of Special Appeals of Maryland
DecidedMay 27, 2021
Docket0355/19
StatusPublished
Cited by6 cases

This text of 252 A.3d 94 (Purnell v. State) is published on Counsel Stack Legal Research, covering Court of Special Appeals of Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Purnell v. State, 252 A.3d 94, 250 Md. App. 703 (Md. Ct. App. 2021).

Opinion

Zamere D. Purnell v. State of Maryland, No. 355, September Term 2019.

CRIMINAL LAW > REVIEW; WEIGHT OF EVIDENCE IN GENERAL In deciding the issue of legal sufficiency of evidence to sustain a conviction, we are dealing only with the satisfaction of the burden of production

CRIMINAL LAW > TRIAL; PROVINCE OF COURT AND JURY IN GENERAL When reviewing the legal sufficiency of evidence to sustain a conviction, we are not concerned with what a factfinder did with the evidence. Rather, we are concerned with what a factfinder could have done with the evidence.

HOMICIDE > FIRST DEGREE, CAPITAL, OR AGGRAVATED MURDER; DELIBERATION AND PREMEDITATION The number of stab wounds to a victim, without more, can constitute legally sufficient evidence to establish premeditation.

HOMICIDE > DELIBERATION AND PREMEDITATION In addition to the number of wounds inflicted, evidence of the intensity of the wounds and the brutal manner in which the wounds were inflicted may also provide sufficient evidence of deliberation and premeditation.

HOMICIDE > DELIBERATION AND PREMEDITATION To establish the deliberate and premeditated elements of first-degree murder, whether a murder defendant acted out of “anger or impulse” is irrelevant, so long as the defendant had sufficient time to reflect on his or her deadly actions.

HOMICIDE > HOMICIDE IN COMMISSION OF OR WITH INTENT TO COMMIT OTHER UNLAWFUL ACT; MURDER; PREDICATE OFFENSES OR CONDUCT; PARTICULAR OFFENSES AND CONDUCT A murder committed in the perpetration of or an attempt to perpetrate robbery is murder in the first-degree. Crim. Law § 2-201(a)(4)(ix).

HOMICIDE > PREDICATE OFFENSES OR CONDUCT In order to sustain a conviction for felony-murder, the intent to commit the underlying felony must exist prior to or concurrent with the performance of the act causing the death of the victim. Accordingly, an afterthought felony will not suffice as a predicate for felony murder. HOMICIDE > PREDICATE OFFENSES OR CONDUCT; DANGEROUSNESS OF OFFENSE IN GENERAL The purpose underlying the modern felony-murder rule is one of deterrence; the rule is intended to deter dangerous conduct by punishing as a first degree murder a homicide resulting from dangerous conduct in the perpetration of a felony, even if the defendant did not intend to kill.

HOMICIDE > PREDICATE OFFENSES OR CONDUCT; CAUSAL RELATIONSHIP BETWEEN OFFENSE AND DEATH Where a defendant’s intent to commit robbery places a victim in a position of defending his person, child, and home, his or her felonious intent to commit the robbery is precisely the type of dangerous conduct the felony-murder rule seeks to deter.

HOMICIDE > PREDICATE OFFENSES OR CONDUCT Where a defendant kills another after entering that victim’s home to commit a robbery, the fact that the defendant ultimately stole less than intended or something other than intended does not place that homicide outside the ambit of the felony-murder rule by virtue of the afterthought-felony exception.

HOMICIDE > PREDICATE OFFENSES OR CONDUCT There is no requirement that the State indict and convict upon the underlying felony to sustain a felony-murder prosecution.

HOMICIDE > PREDICATE OFFENSES OR CONDUCT The felony-murder rule applies to killings committed in the perpetration of or an attempt to perpetrate the enumerated felonies under Crim. Law § 2-201(a)(4).

HOMICIDE > PREDICATE OFFENSES OR CONDUCT Even assuming arguendo that Appellant’s completed robbery was an afterthought, Appellant’s intention to rob Decedent of some other item upon entering Decedent’s home would constitute an attempted robbery, thus providing an independent basis to support Appellant’s felony-murder conviction. Circuit Court for Wicomico County Case No. C-22-CR-18-000230

REPORTED

IN THE COURT OF SPECIAL APPEALS

OF MARYLAND

No. 355

September Term, 2019 ______________________________________

ZAMERE DASHAWN PURNELL

v.

STATE OF MARYLAND ______________________________________

Reed, Friedman, Gould,

JJ.* ______________________________________

Opinion by Reed, J. ______________________________________

Filed: May 27, 2021

Pursuant to Maryland Uniform Electronic Legal Materials Act (§§ 10-1601 et seq. of the State Government Article) this document is authentic. * Leahy, J., did not participate in the Court’s 2021-06-01 decision to report this opinion pursuant to Md. 10:31-04:00 Rule 8-605.1.

Suzanne C. Johnson, Clerk This case comes as an appeal from a bench trial in which Zamere Purnell

(“Appellant”) was found guilty of first-degree murder, robbery, and other related offenses.

The Circuit Court decided Appellant’s first-degree murder conviction on two independent

grounds: (1) the murder was willful, deliberate, and premeditated first-degree murder under

§ 2-201(a)(1) of the Criminal Law Article of the Annotated Code of Maryland (“Crim.

Law”); and (2) Appellant committed the murder during the perpetration of an enumerated

felony set out in Crim. Law § 2-201(a)(4)(i-xii). Following his conviction for first-degree

murder, Appellant timely filed a notice of appeal challenging the sufficiency of the

evidence presented against him at trial. This appeal followed.

In bringing his appeal, Appellant presents one question1 for appellate review which

we have rephrased for clarity:

I. Was the evidence presented against Appellant at trial sufficient to sustain a conviction for first-degree murder under § 2-201(a)(1) or § 2-201(a)(4) of the Maryland Criminal Code?

For the following reasons, we affirm the decision of the Circuit Court.

FACTUAL & PROCEDURAL BACKGROUND

On the morning of March 17, 2018, Pierre Louis (“Decedent”) was found dead on

his bedroom floor. Decedent’s body was first discovered by his brother-in-law, Mr. Lewis,

who was stopping by Decedent’s home to prepare Decedent’s juvenile son for church. Mr.

Lewis testified that Decedent’s son was in his bed, in a neighboring room, when Mr. Lewis

discovered Decedent’s body. Further, Mr. Lewis testified that when he visited Decedent’s

1 In his brief, Appellant posed the following question for review: “Is the evidence sufficient to sustain Mr. Purnell’s conviction for first degree murder? home the previous day, Decedent’s room was in proper order. However, when Mr. Lewis

discovered Decedent’s body, he noted that everything in the room was on the ground as if

there had been a fight. Mr. Lewis also testified that the room emanated a strong smell of

Clorox.

Police arrived on the scene that same morning. After clearing the scene, police

observed Decedent on the floor with a mini fridge partially resting on his head.

Additionally, police observed a dresser tipped over onto the bed. The bed was wet,

discolored, and exuded a strong smell of Clorox. Police also observed several bloody

footprints which tracked from the bedroom to the bathroom, the bathroom to the kitchen,

and continued into another bathroom.

At the scene, police collected the victim’s clothing consisting of a t-shirt and boxer

shorts. The t-shirt displayed small slits in the fabric. A crime scene technician who was on

the scene testified that the two dressers in the room did not appear disturbed or disheveled,

aside from the partial protrusion of the drawers in one dresser, which was found tipped

over on the bed. The technician further testified that she recalled police discovering a

“substantial amount of money” in Decedent’s bedroom.

Thereafter, police canvassed the neighborhood and discovered a dirt path with

shoeprints – consistent with those present at the crime scene – facing towards Appellant’s

home.

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Cite This Page — Counsel Stack

Bluebook (online)
252 A.3d 94, 250 Md. App. 703, Counsel Stack Legal Research, https://law.counselstack.com/opinion/purnell-v-state-mdctspecapp-2021.