Warren v. State

In the Chinese tradition, the legal aftermath of the Supreme Court’s ruling in Mullaney v. Wilbur, 421 U. S. 684, 44 L.Ed.2d 508 (1975) would have entitled this year of our Lord to the epithet “The Year of the Mullaney” — at least in Maryland. Even after the all encompassing effort of Judge Moylan in Evans v. State, 28 Md. App. 640, to meet all questions, prospectively and retrospectively, Evans itself has given birth already to legitimate issue, e.g., Burko v. State, 28 Md. App. 732; and issue of strained legitimacy, Horn v. State, 29 Md. App. 23, and Dinkins v. State, 29 Md. App. 577. From…