WICOMICO COUNTY DEPARTMENT OF SOCIAL SERVICES v. B.A.

WICOMICO COUNTY DEPARTMENT OF SOCIAL SERVICES v. B.A.
Court of Appeals, McDonald, July 12, 2016,
Sexual Abuse (Civil)- FL 5-701 – Sexual abuse by one with temporary responsibility for a child must involve sexually exploitative conduct (or act specifically to facilitate same) during the period of responsibility.

(Dissent – Adkins – civil statute should be considered ambiguous, and therefore expanded in light of legislative intent)
(Dissent – Watts joined by Harrell, anything done during period of responsibility that assists in grooming for sexual exploitation should qualify regardless of demonstrated intent)

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Twigg v. State

DONALD R. TWIGG v. STATE OF MARYLAND
Court of Appeals, Barbera, Filed March 28, 2016,
Child Sexual Abuse – Merger – Where the charging document does not specify which act constituted sexual abuse, the jury was not asked to specify the underlying act, and there are convictions for multiple crimes which could constitute the predicate, merger is necessary on only one of the possible predicate crimes (the one that carries the greatest maximum sentence)