Allen v. State

This case involves the crime of what formerly was referred to as “unauthorized use” of an automobile. The offense has long been a part of Maryland’s statutory criminal law, and for many years could be found at Maryland Code (1957, 1996 Repl.Vol.), Art. 27, § 349. In 2002, the General Assembly reworded and re-codified the offense, and it is now located at Maryland Code (2002), § 7-203 of the Criminal Law Article (“CL”).

Unlike the lengthy description of the conduct prohibited by its predecessor statute, 1 CL § 7-203 is cast in relatively simple terms. The current law defines the prohibited…