In Wagner v. State, 220 Md. App. 174, 190, 102 A.3d 900 (2014), a criminal case affirming the appellant's theft conviction for stealing funds from an account on which the appellant was named as a co-owner, the Court held that "titling an account with two parties listed as 'joint owners' presumptively creates an ownership interest in both parties, but that presumption can be rebutted by evidence of a contrary intent of the original owner of the account." The Court explained that the following standard applies: "In approaching ownership of a bank account prior to the death of one of the parties, the current state of the law requires us to look at the intent of the co-owner and determine if he intended to make an irrevocable gift of ownership of the account. . . . Titling an account as "joint owners" presumptively creates an ownership interest in both parties, but that presumption can be rebutted by evidence of a contrary intent of the original owner of the account." Id. In Wagner, the Court looked to various cases which involved issues relating to ownership rights in the context of joint bank accounts. Id. at 187-90.