Stewart v. United States

YEAGLEY, Associate Judge:

Appellant Stewart was convicted of escape in violation of D.C.Code 1973, § 22-2601 after a trial on stipulated facts. Although the defendant acknowledged that he had failed to return to custody after being issued a temporary pass, he made a proffer of proof that his failure to return was not willful, but involuntary and induced by duress. The trial court found as a matter of law that the proffer, even if proved, would not constitute a valid defense to a charge of escape. Appellant contends that the court erroneously rejected his duress defense. We affirm.

The parties…