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Comment: In The Street Tonight: An Equal Protection Analysis Of Baltimore City's Juvenile Curfew, Andrew Middleman Jan 2015

Comment: In The Street Tonight: An Equal Protection Analysis Of Baltimore City's Juvenile Curfew, Andrew Middleman

University of Baltimore Law Forum

The sun is setting on a late-August evening in Baltimore. Children are playing in the gym at an elementary school in Berea, a small neighborhood in East Baltimore. Ulysses Cofield is watching the clock. Cofield keeps the Fort Worth Elementary School gym open late so the neighborhood kids have a place to blow off steam at the end of the day. At 8:30 p.m., he tells a pair of ten-year-olds they must leave so they can be home within the next thirty minutes. Cofield closes the gym for the evening, then scans the block for lingering children; he wants to …


Recent Development: In Re Tyrell A.: Trial Courts Generally May Not Order Restitution To An Individual Whose Voluntary Participation In A Crime Or Delinquent Act Results In Injury, Andrew Middleman Jan 2015

Recent Development: In Re Tyrell A.: Trial Courts Generally May Not Order Restitution To An Individual Whose Voluntary Participation In A Crime Or Delinquent Act Results In Injury, Andrew Middleman

University of Baltimore Law Forum

The Court of Appeals of Maryland held that Sections 11-601(j) and 11- 603(a) of the Maryland Code, Criminal Procedure Article, do not authorize trial courts to order restitution to an individual who suffers an injury while voluntarily participating in a crime or delinquent act, “absent exceptional circumstances.” In re Tyrell A., 442 Md. 354, 383, 112 A.3d 468, 485 (2015). Accordingly, the court of appeals vacated a juvenile court’s restitution order to an individual who suffered nasal injuries while participating in the common law offense of affray.