Shannon v. State, 209 A.3d 786

On Dec. 10, 2016, the Cannon family paid $2,400 (first month’s rent + security deposit) for 1738 E. 30th St. as they were moving in; appellant Teddy Shannon lived across the street.
While moving in, the Cannons’ vehicle was shot at; appellant displayed a gun, made threats including to burn the house and kill occupants, and was arrested.
The Cannons, fearing for their safety, were escorted off the block by police and never occupied the leased home; they were unable to recover the $2,400 from the landlord.
Appellant was convicted by a jury of threatening arson and possession of a regulated firearm after a disqualifying conviction; sentenced to 17 years and ordered to pay $2,400 restitution for the forfeited deposit and rent.
Appellant challenged (1) the firearm conviction as based on an indictment that misidentified the prior conviction predicate, and (2) the restitution order as not a “direct result” under CP § 11-603(a).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of indictment for firearm possession (predicate conviction mislabeled)	State: drafting error harmless; defendant stipulated to disqualifying prior, so charge was effectively correct	Shannon: indictment misidentified prior as a "crime of violence," so court lacked jurisdiction to convict/sentence	Held: No reversal — defendant’s stipulation cured the drafting error and changed character of charge by consent
Restitution for forfeited deposit & first month's rent	State: loss was a direct result of appellant’s threats; remedial measures were necessary to preserve household security	Shannon: vacating lease was an intervening, voluntary act; loss not a "direct result" and would introduce subjective variability	Held: Restitution affirmed — abandonment of the lease was a direct result of appellant’s threats and the diminished residential security, so CP § 11-603(a) covers the $2,400 loss

Pete v. State, 384 Md. 47 (court declined restitution where victim's later car-collision damages were not a direct result of earlier assault)
Goff v. State, 387 Md. 327 (restitution for property replacement held proper where damage was direct and contemporaneous with crime)
Williams v. State, 385 Md. 50 (restitution vacated where victim’s own failure concerning title, not the theft, caused loss)
Counts v. State, 444 Md. 52 (charging document must characterize the crime and describe conduct; statutory citation alone is not dispositive)
In re Cody H., 452 Md. 169 ("direct result" means no intervening agent or occurrence; restitution cannot be speculative)