BRENDEN DASHIELL v. STATE OF MARYLAND
Court of Special Appeals, Krauser, Filed Nov. 4, 2013,
Affray- Self-defense is a defense to affray

This opinion provides a fairly comprehensive look at the charge of affray (one of only a handful to consider the charge)

Notes on Affray from the case:
– Defined as “the fighting together of two or more persons, either by mutual consent or otherwise, in some public place, to the terror of the people.
– A fight may be deemed “mutual” for purposes of affray by “unlawfully fighting, either by agreement, or hav[ing] brought on the fight himself.”
– The question whether a fight was mutual or self-defense is for the fact finder to determine
– To establish the “terror” element of affray, “[t]error need not actually exist among the people”; rather, “[i]n a legal sense, fighting in public is to the terror of the people.”
– To establish an affray, the State need only show that the acts and surrounding circumstances were “likely to strike terror in anyone,” not that it actually has in any specific individual.
– Self-defense may be invoked as a defense to affray.