Tolan v. State

Quinn Tolen v. State of Maryland Case No. 300 September Term, 2017 Opinion by Meredith, J. CRIMINAL LAW – INVOLUNTARY MANSLAUGHTER BASED UPON UNLAWFUL ACT – SENTENCING – MERGER PURSUANT TO REQUIRED EVIDENCE TEST. In a case in which a conviction of involuntary manslaughter is for the unlawful act variant of that offense, and is based upon the fact that a death was caused by commission of an unlawful act, a conviction for the underlying unlawful act merges into the conviction of involuntary manslaughter for sentencing purposes, and no separate sentence can be imposed for the conviction of the…