State v. Williamson

In State v. Williamson, 282 Md. 100, 101, 382 A.2d 588 (1978), the defendant "employed" someone to kill her husband. After the husband's death, a jury convicted the defendant of first degree murder, conspiracy to murder, and solicitation of murder. Id. at 101. The Court reversed the murder conviction because the State failed "to prove that the appellant herself committed the murder or was either actually or constructively present when the crime was committed." Williamson v. State, 36 Md. App. 405, 407, 374 A.2d 909 (1977), rev'd, 282 Md. 100, 382 A.2d 588 (1978). The Court of Appeals affirmed the validity of the conviction, however, determining that "a person indicted for murder in the form prescribed by Md. Code, Art. 27, 616 may be convicted of murder in the first degree if the accused was only an accessory before the fact." Williamson, 282 Md. at 101.