## Facts

- Marvin Larvae Williams became indebted to a drug organization associated with “Chuckie Eubanks” and previously worked for it, including participating in drug runs to pay down the debt.
- Williams claimed that three armed men abducted him, believed he knew where Eubanks’s drugs were, and threatened to kill him unless he led them to the stash.
- Williams led the men to an apartment occupied by Reverend Chris Glenn Hale in Randallstown, Maryland.
- At about 4:45 p.m. on March 1, 1990, Hale saw Williams through the peephole and partially opened the door after Williams mumbled a question about whether a certain person lived there.
- Four men, including Williams, rushed into the apartment; one placed a gun to Hale’s face, and Hale observed that three intruders were armed, though he did not see a weapon in Williams’s hands.
- The intruders demanded “money” and “dope,” searched the apartment, and left without taking property after holding Hale and Williams at gunpoint.
- Inside the apartment, Williams told the men that the drugs were there, that he and Hale were friends, and that he had used drugs there the prior day.
- In a bench trial, Williams was convicted of attempted robbery with a deadly weapon, daytime housebreaking, and use of a handgun in the commission of a crime of violence; he argued on appeal that he acted under duress and that the docket entries did not accurately reflect the convictions.

## Issues

1. Whether the evidence required acquittal because Williams acted under duress, making the trial court’s rejection of the defense clearly erroneous.
2. Whether the case should be remanded to correct inaccurate docket entries to conform to the actual convictions.

## Decision

- The appellate court affirmed the convictions for attempted robbery with a deadly weapon, daytime housebreaking, and use of a handgun in the commission of a crime of violence.
- The court held that Williams was not entitled to a duress defense because he intentionally or recklessly placed himself in a situation where coercion was probable by voluntarily involving himself with a drug organization and its attendant violence.
- The court also concluded that, even on Williams’s account, the record did not compel acceptance of duress given his active participation in gaining entry and furthering the attempted robbery.
- The case was remanded for the limited purpose of correcting docket entries to accurately reflect the offenses of conviction.

## Legal Principles

- Duress is unavailable when the defendant intentionally or recklessly places himself in a situation in which it is probable he will be subjected to coercion.
- A factfinder may reject a duress claim where the defendant’s conduct shows active participation in the offense rather than compelled, minimal compliance.
- On appellate review of a bench trial, factual determinations are reviewed for clear error, and evidentiary sufficiency is assessed by whether a rational trier of fact could find guilt beyond a reasonable doubt when viewing the evidence in the light most favorable to the State.
- Clerical inaccuracies in docket entries may be corrected on remand without disturbing otherwise valid judgments of conviction.

## Conclusion

The court affirmed Williams’s convictions, holding that duress did not apply because his voluntary involvement with a drug enterprise foreseeably exposed him to coercion and the evidence supported the trial court’s rejection of his compulsion claim; the case was remanded only to correct docket entry errors.


Williams v. State, 101 Md. App. 408, 646 A.2d 1101 (Md. Ct. Spec. App. 1994)