Maryland appears to recognize aider and abettor tort liability, (See Alleco, Inc., et al. v. Weinberg Foundation, Inc., et al., 340 Md. 176, 199, 665 A.2d 1038, 1049 (1995)), it has never been applied to support liability in this context. At least one court has imposed civil liability for murder on an aiding and abetting theory. Halberstam v. Welch, 705 F.2d 472 (D.C.Cir.1983). In Halberstam, the defendant was the live-in companion of a burglar who committed murder during the course of a burglary. Id. at 475. The court held that the defendant was liable for the murder because she knowingly and substantially assisted the burglar in his illicit trade. Id. at 487. Aiding and abetting includes the following elements: (1) the party whom the , 111 S.Ct. 2513, 2517-20, 115 L.Ed.2d 586 (1991) (<HOLDING>); Goldstein v. California, 412 U.S. 546, 571,
holding a suit against an agency of the state is a suit against the state holding that promissory estoppel is applicable only in the absence of an enforceable contract holding that the first amendment does not bar application of ordinary principles of state contract and promissory estoppel law in suit against newspaper for breaching promise of confidentiality and printing a sources name holding that the absence of a binding agreement does not defeat a promissory estoppel claim holding that the issue of whether a contract exists under promissory estoppel is grounded in contract law