Titus v. State
32 A.3d 44
| Md. | 2011Background
- Petitioner Titus Jr. was convicted at Carroll County Circuit Court of obstructing and hindering, DUI per se, DUI by impairment, and giving a false name to an officer.
- State alleged Titus provided a false name during a traffic stop and that officer later discovered Titus had a suspended Maryland license.
- Officer Devivio initiated a traffic stop; Titus produced a Florida license in the name Frederick John Karr, Jr.
- Devivio later learned Titus’s license was suspended; Titus claimed he was a roommate borrowing the motorcycle.
- A later search warrant revealed more about Titus; another officer stated Titus used an alias; Devivio then determined Titus’s real identity.
- The Court of Special Appeals affirmed the obstruction conviction and sentenced the DUI per se; this Court granted certiorari to address sufficiency of the obstruction evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence of false-name provision suffices for obstruction | Titus—lack of actual hindrance; four-part test requires actual obstruction | State—false name obstructs investigation by misidentification and records checks | No; lacked proof of actual obstruction/hindrance beyond a reasonable doubt |
| Whether the four-part test from Cover applies to all obstruction categories | Test applies to all categories of obstruction | Test may be inapplicable to some indirect/negative hindrance cases | Yes; four-part test applies regardless of obstruction category |
| Whether the State proved knowledge and intent elements beyond a reasonable doubt | Titus knew officer acted in official duties and intended to obstruct | Knowledge/intent inferred from actions but not shown to hinder | Knowledge established; intent inferred but actual obstruction missing |
Key Cases Cited
- Cover v. State, 297 Md. 398, 466 A.2d 1276 (Md. 1983) (four-part test for obstructing an officer in duty performance)
- Antoine H. v. State, 319 Md. 101, 570 A.2d 1239 (Md. 1990) (discusses adequacy of evidence to show actual hindrance)
- Nievas v. State, 160 Md.App. 647, 866 A.2d 870 (Md. App. 2004) (evidence of lack of hindrance insufficient where no actual obstruction)
- Sheinbein v. Md., 372 Md. 224, 812 A.2d 981 (Md. 2002) (analyzes intent element; establishes inference from prohibited acts)
- DiPino v. Davis, 354 Md. 18, 729 A.2d 354 (Md. 1999) (knowledge element requires officer engaged in duties; not mere contact)