ANNAPOLIS – The Maryland Court of Special Appeals upheld a teen’s murder and robbery convictions, even though the judge in his trial told jurors they did not have to determine guilt or innocence “to any degree of certainty.”
The appellate court said Tuesday that Prince George’s Circuit Judge Arthur M. Ahalt’s instructions, taken as a whole, made clear that jurors should be convinced beyond a reasonable doubt before convicting Willie Love Hamilton.
Hamilton was 16 when he was charged with murder, robbery, conspiracy to commit robbery and weapons charges in the Feb. 26, 1992, killing of a convenience store cashier.
Prosecutors said Hamilton and an accomplice, Shawn Goodman, plotted the robbery of the Metro Food Store at 5911 Central Ave. in Prince George’s County.
According to court documents, Goodman went in posing as a customer, followed by Hamilton, who was wielding a sawed-off shotgun. The two demanded and got money from the cashier, Uwaoma Elue, dropping most of it on the floor in the process.
When Elue made a sudden move, Hamilton later told police, he shot at him. The single blast hit Elue in the head, killing him.
After police found the murder weapon, a .410-gauge sawed-off shotgun, at Goodman’s home, he fingered Hamilton as the triggerman. Hamilton turned himself in and, after questioning, gave a tearful confession to police, according to court records.
Hamilton was convicted and sentenced to life for murder, 20 years for a handgun conviction and 10 years for conspiracy to commit robbery.
Hamilton’s trial attorney, Michael Conway, did not object to Ahalt’s instructions, even after the judge asked if there were any exceptions to them. Conway said Tuesday he did not object because he found nothing inappropriate in Ahalt’s instructions.
“Obviously, the appeals court agreed with me,” he said. “It was a really sad case.”
But Hamilton’s attorney on appeal, Therese L. Staudenmaier, argued that the convictions should be thrown out because Ahalt’s explanation of reasonable doubt “is an obvious misstatement of the state’s burden of proof.”
She also criticized the judge’s directions as incoherent, arguing that the lack of clarity “denied the jury an essential tool to decide the defendant’s fate.”
But a three-judge panel of the appeals court ruled that Ahalt’s instructions met standards for jury instruction in a criminal case.
The Maryland Pattern Jury Instructions say “the state is not required to prove guilt beyond all possible doubt or to a mathematical certainty.” The appeals court said Ahalt’s instructions did not demean or trivialize the seriousness of the reasonable doubt standard.
Hamilton is likely to appeal Tuesday’s ruling, said Staudenmaier.
If that is unsuccessful, she said, he plans to file another appeal in Prince George’s County claiming that Conway did not adequately represent him. Conway denies that charge.