State v. Sowell

I concur only in the judgment of the Court. I agree with the majority that the evidence was insufficient to establish that Sowell was a principal in the first or second degree and that, under the current state of the law in Maryland, his conviction must be reversed. I part company with the majority, however, because I believe that the time has come for this Court to abolish the common law distinction in charging between principals and accessories.

*735Twenty-two years ago, two distinguished Maryland jurists called for the abolition of the useless common law distinction between principals and…