## Facts

- Police conducted surveillance of banks in an area experiencing multiple robberies.
- Officers observed Raymond Alexander Young repeatedly driving around banks in a manner suggesting he was “casing” them.
- Young parked near a bank and put on items used as a disguise, including a knit cap pulled down over his forehead, an eyepatch, plastic surgical gloves, sunglasses, and a turned-up shirt collar.
- Young approached the bank with his right hand in his jacket pocket and his left hand partially covering his face.
- Unaware the bank had closed, Young tried to open the bank’s front door; finding it locked, he fled while covering his face.
- Police stopped Young as he drove away; a .22 caliber pistol butt was visible from his jacket pocket.
- Officers found disguise items on the front seat, including surgical gloves, an eyepatch, a knit cap, and sunglasses.
- Evidence included that Young had previously inquired about punishment for attempted robbery.

## Issues

1. Whether the evidence was legally sufficient to prove attempted armed robbery, specifically whether Young committed an overt act beyond mere preparation.
2. What standard governs criminal attempt in Maryland for distinguishing preparation from an attempt (including whether conduct constituting a “substantial step” suffices).

## Decision

- The Court of Appeals of Maryland affirmed the conviction for attempted armed robbery (and the related handgun conviction).
- The court held that Young’s conduct went beyond preparation and constituted a substantial step toward committing armed robbery.
- The court concluded that attempting to open the bank door while armed and disguised was an overt act strongly corroborative of intent to rob.

## Legal Principles

- Criminal attempt requires intent to commit a specific offense and an overt act that goes beyond mere preparation.
- The act element is satisfied when the defendant takes a “substantial step” toward commission of the crime—conduct strongly corroborative of criminal intent—even if external circumstances prevent completion.
- Reconnaissance and acquisition of tools may be preparatory; arriving at the target and beginning execution (such as attempting entry while armed and disguised) can constitute a substantial step.

## Conclusion

The court upheld Young’s attempted armed robbery conviction because his armed, disguised approach to the bank and attempt to open its locked door constituted a substantial step beyond preparation and objectively confirmed his intent to commit the robbery.


Young v. State, 303 Md. 298, 493 A.2d 352 (Md. 1985)