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Street v. State | 307 Md. 262 (1986)
Fines are typically imposed for minor offenses, such as parking tickets or speeding tickets. In Street versus State, we’ll see whether fines can also be imposed after a defendant is convicted of common-law false imprisonment.
George Street was a taxicab driver. One day in 1983, Valerie McNeal entered Street’s cab. When McNeal got to her destination, her cab fare totaled $2.50. McNeal only had $2.46, one $10 bill, and one $20 bill. McNeal offered to pay Street with the $10 bill. Street refused to accept the $10 bill, claiming that he couldn’t give McNeal proper change because a city ordinance didn’t require him to carry more than $5 in change. McNeal suggested that they get change from a nearby business, but Street refused. As McNeal was attempting to leave the cab, she noticed that all the doors were locked. McNeal repeatedly asked Street to let her out of the cab, but Street wouldn’t unlock the doors. Street kept McNeal locked in the cab for around 25 minutes. Street eventually let McNeal go after a passerby intervened and the police arrived at the scene.
The State of Maryland charged Street with false imprisonment. Street was later tried and convicted in Maryland state court. In Maryland, false imprisonment is a common-law offense without a statutorily prescribed penalty. After the trial court judge examined Street’s conduct, as well as Street’s financial situation in relation to his ability to pay a fine, the judge sentenced Street to three years of probation and a $500 fine. Street appealed. The Maryland Court of Special Appeals affirmed. Street appealed again, claiming that a fine isn’t a recognized common-law punishment for false imprisonment. The Maryland Court of Appeals granted cert.
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