Clark v. State

Jamel Clark v. State of Maryland No. 23, September Term 2020 Criminal Law – Sentencing – Merger of Convictions – Required Evidence Test. A conviction for the crime of possession of an assault weapon does not merge into a conviction for possession of a firearm by a convicted drug felon under the required evidence test, even though both convictions are based on possession of the same weapon. Maryland Code, Criminal Law Article, §§4-303, 5-622. Criminal Law – Sentencing – Merger of Convictions – Rule of Lenity. The rule of lenity is used as a last resort when the ordinary tools of statutory…