Evans v. State

It was but a matter of time before the common law’s crazy quilt of murder and manslaughter — eight hundred years in the making and intricately interweaving Stuart modification of Tudor substance with Victorian adaptation of Georgian procedure — would come under the cold glare of latter-day due process. That time came on June 9, 1975, with the Supreme Court’s decision in Mullaney v. Wilbur, 421 U. S. 684, 95 S. Ct. 1881, 44 L.Ed.2d 508 (1975). The conviction of Edward Evans, appellant, by a Baltimore City jury for murder in the second degree gives us occasion to assess the impact of Mullaney…