Muir v. State

“Ambiguity in statutes may not be the parent of litigation, but it is certainly a kissing cousin.” 1

The late Judge John P. Moore, writing for this Court in Calhoun v. State, 46 Md.App. 478, 418 A.2d 1241 (1980), aff'd, 290 Md. 1, 425 A.2d 1361 (1981), characterized the “draftsmanship” of Md.Ann.Code art. 27, § 643B(c) as “patently inartful.” “Any change,” he wrote, “must be left to the legislature.” Calhoun, 46 Md.App. at 490, 418 A.2d at 1249, aff'd 290 Md. 1, 425 A.2d 1361. That body heeded Judge Moore’s implicit invitation, but it, nevertheless, failed to clarify completely § 643B(c). As a…