In re Devon T., 584 A.2d 1287 (Md. Ct. Spec. App. 1991)

Facts: 13-year-old Devon T. was found at school with 20 pellets of heroin in his pants. He was adjudicated delinquent for possession with intent to distribute. He invoked the common-law infancy defense, arguing the State had not rebutted the presumption of incapacity that applies to children between 7 and 14.
Issue: Whether the State produced sufficient evidence to rebut the common-law presumption of infancy and prove that Devon understood the wrongfulness of his act.
Rule: At common law, children 7 to 14 are rebuttably presumed incapable of criminal intent. The State must prove ∆ knew the act was wrong by clear and convincing evidence.
Analysis: Devon's age (13.5—near the upper bound), his behavior (concealing the drugs in his pants, attending school, the substantial quantity), the inherent moral and legal awareness suggested by his actions, all supported finding he knew right from wrong. Quantity alone showed sophistication beyond a child playing with what he didn't understand.
Judgment: Adjudication affirmed; presumption rebutted.

Reading: pp. 696–704. See Infancy.