Supreme Court of Maryland
Nguyen v. State
July 30, 2025
Summary
The court reversed Nguyen’s reckless-endangerment conviction because the State failed to prove that he owed Brown a legal duty to prevent an unforeseeable, spontaneous assault by a third person. The court also held that Brown was not in Nguyen’s custody and therefore no special relationship created a duty owed directly to Brown. Because the duty element was not established, the court did not address whether Nguyen’s conduct otherwise satisfied the remaining elements of reckless endangerment.