McNeal v. State
426 Md. 455
| Md. | 2012Background
- McNeal was convicted of possessing a regulated firearm after a prior disqualifying crime and of resisting arrest, but acquitted of wearing, carrying, or transporting a handgun; jury deemed the two counts inconsistent.
- McNeal argued Price v. State (inconsistent verdicts ban) should bar factually inconsistent verdicts, not just legally inconsistent ones.
- Trial judge declined to treat the verdict as prohibited; State relied on Price’s scope, arguing only legally inconsistent verdicts are banned.
- Maryland Court of Appeals held Price does not apply to factually inconsistent verdicts in criminal trials and allows the factually inconsistent verdict here to stand.
- Court emphasized jury as sole fact-finder and warned trial judges not to intrude on jury deliberations to “correct” factual inconsistencies.
- Holding preserves historic jury role and limits reversed outcomes to legally inconsistent verdicts only.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Price prohibits factually inconsistent verdicts | McNeal relies on Price to bar factually illogical verdicts | State argues Price bans only legally inconsistent verdicts | Price does not apply to factually inconsistent verdicts |
| Whether McNeal's verdicts were factually inconsistent | Acquittal on wearing/carrying a handgun vs. conviction on possession after disqualifying crime shows illogic | No legal element overlap; no lesser-included offense; facts not intruding on law | Verdicts are factually inconsistent but legally permissible; cannot remand for factual resolution |
| Collateral estoppel or appellate review implications | Ashe/Dunn framework could preclude subsequent prosecutions on related theories | Single-trial context prevents collateral estoppel from applying | Collateral estoppel does not dictate outcome; review respects jury’s fact-finding in a single trial |
Key Cases Cited
- Price v. State, 405 Md. 10 (2008) (holding inconsistent verdicts not allowed in criminal trials (legal inconsistencies))
- Williams v. State, 397 Md. 172 (2007) (in bench trials, inconsistent verdicts disallowed; jury-trial deference noted)
- Mack v. State, 300 Md. 583 (1984) (trial court may set aside verdict for misapplication of law)
- Dunn v. United States, 284 U.S. 390 (1932) (collateral estoppel principles; limits in multi-indictment scenarios)
- Powell v. United States, 469 U.S. 57 (1984) (courts may not infer jury lenity; concerns over remanding for factual resolution)
- Ashe v. Swenson, 397 U.S. 436 (1970) (collateral estoppel principles in criminal context)
- Muhammad v. State, 935 N.Y.S.2d 526 (2011) (New York approach to repugnant verdicts (not Maryland, cited for comparison))
- State v. Halstead, 791 N.W.2d 805 (Iowa 2010) (limits on review of certain inconsistent verdicts (Iowa approach))