Harris v. State
| Decision Date | 08 June 2022 |
| Docket Number | 45-2021 |
| Parties | DAWNTA HARRIS v. STATE OF MARYLAND |
| Court | Maryland Court of Appeals |
Getty, C.J., [*] Watts, Hotten, Booth, Biran, Battaglia, Lynne A. (Senior Judge, Specially Assigned) McDonald, Robert N. (Senior Judge, Specially Assigned) JJ.
When he was sixteen years old, Dawnta Harris, Petitioner, skipped school and joined three teenage companions in driving a stolen Jeep to commit a series of burglaries in Baltimore County. In an attempt to evade Baltimore County Police Officer Amy Caprio, who had responded to the location of one of the burglaries, Petitioner drove the stolen Jeep into a neighborhood cul-de-sac. While Officer Caprio tried to prevent Petitioner from exiting the cul-de-sac, Petitioner ran her over with the Jeep and killed her. Petitioner was convicted by a jury in the Circuit Court for Baltimore County of first-degree felony murder, first-degree burglary, and the theft of the Jeep. He was sentenced to life in prison with the possibility of parole for the first-degree felony murder of Officer Caprio, plus twenty years and five years, respectively, for his convictions of first-degree burglary and theft of the Jeep, to be served concurrently with the life sentence.
After the Court of Special Appeals affirmed Petitioner's convictions, he filed a petition for writ of certiorari to this Court, presenting the following questions for our review:
We granted certiorari and, as explained in detail below, answer the first question in the negative. Pertaining to the second question, we determine that the Eighth Amendment does not impose an individualized sentencing requirement for juveniles sentenced to life imprisonment with the possibility of parole. We therefore affirm the decision of the Court of Special Appeals.
On May 21, 2018, Petitioner skipped school and committed a series of day-time burglaries in Baltimore County with three other teenagers, utilizing a black Jeep Wrangler that had been stolen three days prior. Officer Amy Caprio of the Baltimore County Police Department arrived at a home on Linwen Way in the Parkville Area of Baltimore County, in response to a 911 call by a neighbor who had reported unfamiliar individuals walking around the periphery of the house and looking into its windows. Petitioner stayed in the Jeep outside the Linwen Way home while his companions walked around the house. When Petitioner observed Officer Caprio's vehicle approaching he drove away.
Officer Caprio followed the Jeep, which drove into a cul-de-sac in the neighborhood. She positioned her vehicle before getting out, so that it was partially blocking the exit of the cul-de-sac. The Jeep turned around at the end of the cul-de-sac and drove directly towards Officer Caprio. Officer Caprio drew her weapon and ordered Petitioner to stop and get out of the Jeep. Initially, the Jeep stopped directly in front of Officer Caprio, and Petitioner opened the driver's side door. Officer Caprio stepped in front of the Jeep, keeping her weapon drawn. Petitioner then shut the door, accelerated, struck Officer Caprio, and drove away. Officer Caprio fired one gunshot, which struck the front windshield of the Jeep at nearly the same moment she was hit by the Jeep. Neighbors who observed the incident rushed to Officer's Caprio's aid, and she was transported to the hospital, but ultimately died from her injuries.
Another neighbor, Christopher Squires, unaware of the above referenced events, observed a black Jeep with a bullet hole on the driver's side windshield travelling quickly down the street. He then observed the driver, who matched Petitioner's description, park and walk away from the vehicle without entering any house. The neighbor found this behavior suspicious and called the police. A police officer responding to that call picked up Petitioner walking in the neighborhood, and he was identified by Mr. Squires as the individual who abandoned the Jeep. Various stolen items were later recovered from inside the Jeep.
When interviewed by police, Petitioner initially denied knowing anything about the Jeep, but later changed his story. He told detectives that some of his friends showed up with the Jeep, that he did not know it was stolen, and that when they drove to various houses, he stayed in the car. He claimed that he did not know what his friends were doing, although he knew it was something that they were not supposed to be doing. Petitioner then alleged that, while waiting in the car, he saw a police officer approach and decided to drive off. He described turning around at the cul-de-sac and seeing a female police officer get out of her car and point a gun at him. He stated that he was too scared to get out of the car, that he put his head down, closed his eyes, and could not hear what the officer was saying. Petitioner described the incident in the following way:
Petitioner was sixteen years old at the time of the incident.
Petitioner was charged in the Circuit Court of Baltimore County with first-degree felony murder, two counts of first-degree burglary, one count of fourth-degree burglary, and theft of the Jeep.[1] A jury trial was held between April 22, and May 1, 2019. With respect to the first-degree felony murder, the State explained in closing that:
It's not necessary for the State to prove the Defendant intended to kill. The State has to prove that others participating in the crime with Defendant committed a felony, and that felony is first-degree burglary; Defendant killed Officer Caprio; the act resulting in the death of Officer Caprio occurred during the escape of the first-degree felony burglary. Felony murder.
The jury instructions likewise specified that it was not necessary for the jury to find Petitioner intended to kill Officer Caprio in order to find him guilty of felony murder.[2] Petitioner was found guilty of first-degree felony murder, one count of first-degree burglary, and the theft of the Jeep.[3] A sentencing hearing was held on August 21, 2019, during which defense counsel presented mitigating evidence, including various references to Petitioner's young age, the negative influences in his life, his ability to change, as well as a letter written by Petitioner in which he described his own undeveloped decision-making due to his age. A pre-sentence investigation was also submitted, which provided, among other things, Petitioner's age, criminal history, personal history, current family situation, educational history, and mental health issues. The sentencing court stated that, "[h]aving considered the pre[-]sentence investigation, the victim impact [statement], the Defendant's prior record, the arguments of counsel, [and] the allocution[, ]" it sentenced Petitioner to life in prison with the possibility of parole for the felony-murder conviction, twenty years for first-degree burglary, and five...
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