## Facts

- A Baltimore taxicab passenger hired George Street to drive her to her destination.
- The fare was $2.50; the passenger had $2.46 in coins and offered a ten-dollar bill to pay.
- Street refused the ten-dollar bill, citing a rule limiting required change, and refused to let either party obtain change nearby.
- When the passenger tried to exit, she found the rear doors locked and could not open doors or windows due to Street’s control of locks and a plexiglass partition.
- Street kept the passenger in the cab for about 25 minutes while the meter continued running, acted abusively and threateningly, and refused repeated requests to unlock the doors.
- A passerby intervened; Street then accepted the ten-dollar bill for the increased fare (about $5.20), gave $5 change, and released the passenger; police arrived shortly after.
- After a bench trial, Street was convicted of common-law false imprisonment and sentenced to one year incarceration (suspended), three years’ probation, and a $500 fine.

## Issues

1. Whether a Maryland court may impose a fine for a common-law misdemeanor (false imprisonment) when no statute prescribes a penalty for that offense.

## Decision

- The Court of Appeals of Maryland affirmed.
- The court held a fine may be imposed as punishment for the common-law crime of false imprisonment even without a statutorily specified penalty.
- The $500 fine was upheld as a permissible exercise of sentencing discretion and not constitutionally excessive.

## Legal Principles

- Maryland courts may sentence for common-law crimes in the absence of statutory penalties, and the sentencing court retains broad discretion subject to constitutional limitations.
- Fines are a historically recognized common-law punishment for misdemeanors and remain available unless the legislature has restricted that authority.
- The penalty scheme for a related statutory offense does not, by itself, limit sentencing options for a distinct common-law offense.
- Sentences for common-law crimes are constrained by prohibitions on cruel and unusual punishment and general proportionality concerns.

## Conclusion

The court upheld a sentence including a fine for common-law false imprisonment, ruling that when no statute fixes punishment, Maryland trial courts may impose traditional common-law penalties—including fines—so long as the sentence remains within constitutional bounds.


Street v. State, 307 Md. 262, 513 A.2d 870 (Md. 1986)