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 Concurrent intent theory emerged from the discussion in Ford v. State, 330 Md. 682, 625 A.2d 984 (1993), in which the Court expressed its disapproval of the use of 'transferred intent' in cases where the defendant faced charges of attempted murder of a bystander. See LeEllen Coacher & Libby Gallo,   Criminal Liability: Transferred and Concurrent Intent, 44 A.F.L. REV. 227, 235 (1998). The Ford Court discussed the doctrine of 'concurrent intent' to 'explain[] and justify' the result in State v. Wilson, 313 Md. 600, 546 A.2d 1041 (1988), the case in which this Court held that 'transferred intent' could be used to prove the specific-intent element of attempted murder of a bystander. Ford, 330 Md. at 716, 625 A.2d at 1000. Explaining the distinction between 'transferred intent' and 'concurrent intent,' Judge Chasanow for the Court stated: In transferred intent, the intended harm does not occur to the intended victim, but occurs instead to a second . . . victim. The actual result is an unintended, unanticipated consequence of intended harm. For example, consider a defendant who shoots a single bullet at the head of A, standing with B and C. If the defendant misses ...

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