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The kill zone theory is not unique to California. Although the kill zone theory is used most frequently in California, it originated in Maryland. In Ford v. State, the Maryland Court of Appeal noted that in a case of attempted murder, intent could be concurrent if the perpetrator intended to kill the primary target by creating a kill zone whereby he intended to harm everyone in the target’s vicinity in order to ensure the death of the primary target.

Interestingly, the Maryland Court of Appeals relied on California case law in order to formulate the kill zone theory in Ford. People v. Bland, a 2002 California case, incorporated Ford’s kill zone theory into California case law and created this frequently misapplied doctrine. 

Courts in Alabama, Illinois, Kansas, Pennsylvania, Tennessee, and Virginia have discussed the kill zone theory in attempted murder cases. Maryland has used the kill zone theory in only a few cases, whereas there have been several hundred kill zone cases in California. Although the kill zone theory was first created in Maryland, it is utilized most often in California and has had the greatest impact on California defendants.