Mayfield v. State

ELDRIDGE, Judge.

The question presented in this criminal case is whether, after a jury informs the trial judge that it is deadlocked and discloses the numerical majority-minority division, it is erroneous as a matter of law for the trial judge to give an Allen -type charge in the form recommended by the American Bar Association (ABA).

The underlying facts, taken largely from the parties’ agreed statement of facts pursuant to Maryland Rule 828 g, are as follows. Louis Garland Mayfield was indicted in the Circuit Court for Prince George’s County for attempted armed robbery and related offenses,…