## Facts

- In the early morning of May 27, 1990, Maurice Edward Ford and several other youths stood on or near the Capital Beltway and threw large landscaping rocks at passing vehicles.
- The rock-throwing occurred between approximately 2:00 and 3:00 a.m., lasted roughly 30 to 45 minutes, and struck an estimated 15 to 40 vehicles.
- Many vehicles sustained significant damage, and multiple occupants suffered injuries.
- Ford was indicted on numerous counts, including assault with intent to murder, assault with intent to maim, assault with intent to disable, assault and battery, and malicious destruction of property.
- A jury convicted Ford of assault with intent to maim, multiple counts of assault with intent to disable, assault and battery, assault, and multiple malicious-destruction offenses; the court imposed an aggregate sentence totaling 39 years, with additional suspended time and probation.
- The trial court instructed the jury that if it found Ford intended to disable vehicle drivers, that intent could be transferred to passengers; Ford did not object to the instruction.
- On intermediate appeal, most convictions were affirmed; review was granted to address issues concerning the remaining convictions.

## Issues

1. Whether the doctrine of transferred intent applies to specific-intent assault offenses requiring intent to cause a particular type of harm (e.g., intent to maim or disable) when unintended victims are injured.
2. Whether transferred intent is necessary or proper when the intended victim is actually harmed and additional victims are also harmed in the same incident.
3. How transferred intent differs from concurrent intent in multi-victim scenarios, and which concept properly explains liability where others are foreseeably in the line of fire.

## Decision

- The Court of Appeals of Maryland affirmed Ford’s remaining convictions.
- The court held that transferred intent can apply to specific-intent crimes, but only as a gap-filling doctrine that joins intent toward one person with harm to another.
- The court further held that when the crime is actually committed against the intended victim, transferred intent is unnecessary and should not be applied.
- The court distinguished transferred intent from concurrent intent, explaining that concurrent intent may support liability for additional victims when others are clearly within the path of the defendant’s attack.
- The court concluded that no reversible error warranted disturbing Ford’s convictions.

## Legal Principles

- Transferred intent may be used for specific-intent crimes to combine the intent directed at an intended target with the harm inflicted on a different, unintended victim.
- Transferred intent should not be applied when the intended victim is actually harmed, because there is no missing element requiring a doctrinal “transfer” to complete the offense.
- In multi-victim events, concurrent intent may exist where a defendant targets one person while also intending to harm others who are plainly in the line of the attack.
- Courts should not treat transferred intent as a general method for multiplying specific-intent liability across multiple victims when the theory does not match the defendant’s intent structure.

## Conclusion

The court affirmed Ford’s convictions arising from a multi-vehicle rock-throwing episode and clarified that transferred intent is a limited doctrine for specific-intent crimes, inappropriate when the intended victim is actually harmed; multi-victim liability may instead rest on direct proof of intent or concurrent intent where others are foreseeably in the path of the attack.


Ford v. State, 625 A.2d 984 (Md. 1993)