Wild v. State, 201 Md. 73

Summary

The Maryland Court of Appeals affirmed the conviction of a ship's First Assistant Engineer for permitting fuel oil to discharge into Baltimore Harbor in violation of state law. The court held that the evidence was legally sufficient to support an inference of knowledge, including the defendant's responsibility for the fuel-loading operation and his reported awareness of the oil slick before pumping ceased.

Holdings

1. The evidence was legally sufficient to support a finding that the First Assistant Engineer had actual knowledge that oil was in the water alongside the ship and was escaping from the ship; therefore, the motion for a verdict of not guilty was properly denied.
2. The court did not decide whether scienter was an element of the statute; assuming without deciding that scienter was required, the evidence was sufficient to establish it.

Questions Presented

1. Whether the State's evidence was legally sufficient to support Wild's conviction for discharging or permitting the discharge of oil into Baltimore Harbor.
2. Whether knowledge or scienter, if required by the State water-pollution statute, could be inferred from circumstantial evidence despite Wild's denial of knowledge.

Disposition

affirmed