Towson, Maryland Criminal Lawyers

Brian G. Thompson
PREMIUM

Maryland Criminal Law Attorney with 23 years experience

University of BaltimoreMaryland and United States District Court, District of Maryland
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James E Crawford Jr.
PREMIUM

Maryland Criminal Law Attorney with 27 years experience

Attorney James E. Crawford, Jr. Founder and Managing Partner As a Baltimore-native, Attorney James Crawford grew up watching his father interact with some of the best judges and prosecutors in the state, using... Read More »
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Andrew C. White
PREMIUM

Free Consultation! Criminal Defense Attorney Committed to Exceptional Results!

I have provided legal expertise and experience for over 25 years. I zealously fight for the rights and interests of criminal defendants! Visit my website for settlements and verdicts, and call for a free consultation! Read More »
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Kevin W. Young
PREMIUM

Maryland Criminal Law Attorney with 25 years experience

University of Maryland Francis King Carey School of LawMaryland and District of Columbia
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Stephen P. Shepard
Claimed Lawyer ProfileQ&ASocial Media
Towson, MD Criminal Law Lawyer
(410) 648-4008 303 W. Pennsylvania Ave.
Towson, MD 21204
Free ConsultationCriminal, DUI, Domestic Violence and Traffic Tickets
Appalachian School of Law
Stephen P. Shepard is a Maryland criminal defense attorney and the owner of The Law Office of Stephen P. Shepard, LLC. He has extensive experience in handling criminal, DUI/DWI, serious traffic, and violation of probation cases. Additionally, he has zealously represented clients at bail review hearings, modification of sentence hearings, and various other legal proceedings. Before founding his own law office, he served as a full-time volunteer attorney for the Maryland Office of the Public Defender. As a volunteer attorney, he personally handled hundreds of cases in the District Court Division of the Howard County office, and later, the Baltimore...
Richard M. Karceski
Claimed Lawyer ProfileLII GoldBlawgsearchSocial Media
Towson, MD Criminal Law Attorney with 50 years experience
(410) 494-7100 1 W Pennsylvania Ave
#905
Towson, MD 21204
Free ConsultationCriminal, DUI and White Collar Crime
University of Baltimore School of Law
Justin Esworthy
Claimed Lawyer ProfileLII GoldSocial Media
Towson, MD Criminal Law Attorney with 13 years experience
(410) 567-0694 29 W. Susquehanna Ave.
Suite 402
Towson, MD 21204
Free ConsultationCriminal, DUI, Traffic Tickets and White Collar Crime
Tulane University School of Law
Justin W. Esworthy is a founding Member of TBH&E with extensive litigation experience, having tried hundreds of cases throughout the State of Maryland and Commonwealth of Virginia. Justin has obtained favorable results for both civil and criminal clients through both pre-suit representation as well as trial victories. Prior to law school, Justin studied in Buenos Aires, Argentina and obtained his B.B.A from Hofstra University. He earned his J.D. from Tulane University Law School and then began his law career in the courtroom as an Assistant Public Defender representing clients on charges ranging from minor misdemeanors to serious felonies that...
Lee Eidelberg
Claimed Lawyer ProfileQ&ASocial MediaResponsive Law
Towson, MD Criminal Law Lawyer with 35 years experience
(410) 321-0600 502 Washington Avenue
Towson, MD 21204
Free ConsultationCriminal, DUI, Domestic Violence and Traffic Tickets
University of Baltimore School of Law
Lee J. Eidelberg is a former Assistant State's Attorney for Baltimore County with extensive experience in criminal and traffic court, having prosecuted many hundreds of cases during his tenure in public service, including serious felonies and misdemeanor violations. Since entering private practice more than 20 years ago, Lee has brought a unique combination of extensive trial skills, passion, and commitment to protecting his clients' rights, whether defending CDL holders charged with federal regulation violations, common motorists charged with DUI, or appearing on behalf of both Maryland and out-of-state drivers charged with non-incarcerable moving violations. Lee also assertively pursues financial...
Kerri Bloom Cohen
Claimed Lawyer ProfileSocial MediaResponsive Law
Towson, MD Criminal Law Lawyer with 17 years experience
(410) 657-2515 606 Baltimore Avenue
Suite 407
Towson, MD 21204
Criminal, DUI, Family and Traffic Tickets
University of Baltimore School of Law
As a native of Baltimore, Maryland, Attorney Cohen has been practicing here for over 17 years. She established the Law Offices of Kerri Cohen after working for 11 years for the State of Maryland in Baltimore City at the Office of the Public Defender as an experienced criminal defense trial attorney. She represented clients charged with serious felonies such as homicide, rape, robbery and drug charges among other crimes. Attorney Cohen has tried hundreds of cases before Judges and Juries in the Circuit Court, District Court and Juvenile Courts.

Attorney Cohen graduated Magna Cum Laude from the University of...
William A. Stavros
Claimed Lawyer ProfileLII GoldSocial Media
(410) 825-3300 502 Washington Ave
#730
Towson, MD 21204
Free ConsultationTowson, MD Criminal Law Lawyer with 22 years experience
Criminal, DUI, Personal Injury and Traffic Tickets
University of Maryland Francis King Carey School of Law
Rene E.B. Tywang
Claimed Lawyer Profile
Towson, MD Criminal Law Attorney with 10 years experience
(410) 583-8800 300 E. Joppa Rd.
Suite 305
Towson, MD 21286
Criminal, DUI and Family
University of Baltimore School of Law
Richard Kevin Scott
Claimed Lawyer Profile
Towson, MD Criminal Law Attorney with 19 years experience
(410) 337-5291 40 W Chesapeake Ave
Suite 506
Towson, MD 21204
Criminal, DUI, Divorce and Domestic Violence
Wake Forest University School of Law
Dilip Paliath
Claimed Lawyer ProfileSocial Media
Towson, MD Criminal Law Attorney with 22 years experience
(410) 494-1494 307 W. Pennsylvania Ave.
Towson, MD 21204
Criminal, Business, DUI and Estate Planning
University of Virginia School of Law
Craig Patrick Ward
Claimed Lawyer Profile
Towson, MD Criminal Law Attorney with 20 years experience
(410) 823-1800 102 W Pennsylvania Ave
Towson, MD 21204
Criminal, DUI, Divorce and Family
University of Baltimore
Thomas Joseph Maronick Jr
PREMIUM

Maryland Criminal Law Lawyer with 11 years experience

Thomas Maronick Jr is a Super Lawyers-rated attorney who has been practicing since 2008. A Baltimore native, Mr. Maronick is the founder and managing partner of The Law Office of Thomas Maronick Jr, LLC. Mr. Maronick... Read More »
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Steven D. Silverman
PREMIUM

Free Consultation! Competent, Experienced Criminal Defense Attorney! Call Now!

I provide exceptional legal services in all areas of criminal defense. I provide skilled and aggressive representation for the criminally accused! Call for a free consultation, see my website for excellent case results. Read More »
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David D Nowak
Claimed Lawyer ProfileSocial Media
Towson, MD Criminal Law Attorney with 10 years experience
(443) 470-9071 300 E. Joppa Rd.
Suite 303
Towson, MD 21286
Criminal, Appeals, Business and Family
David was born and raised in Baltimore. He attended Calvert Hall College High School and Graduated from Towson University with a B.A. in International Studies. After spending over 5 years as a Securities Analyst for a Fortune 500 Financial Firm, he attended the University of Baltimore School of Law. During law school David was a student attorney for three semesters with the University's Family Law Clinic. There, he argued cases for economically disadvantaged clients in the District Court, Circuit Court, and the Court of Special Appeals. David also participated in a campaign to reform Maryland's Domestic Violence laws, and was...
Marc Elliot Mandel Esquire
Claimed Lawyer Profile
Towson, MD Criminal Law Lawyer with 19 years experience
(866) 575-7854 219 W Joppa Rd
Suite 200
Towson, MD 21204
Criminal, Administrative, DUI and Real Estate
David Greenbaum
Claimed Lawyer Profile
Towson, MD Criminal Law Lawyer with 30 years experience
(410) 321-8400 409 Washington Avenue
Suite 300
Towson, MD 21204
Free ConsultationCriminal, DUI and Personal Injury
University of Baltimore School of Law
Thomas Campbell Morrow
Claimed Lawyer Profile
Towson, MD Criminal Law Attorney with 44 years experience
(410) 823-9406 102 W Pennsylvania Ave
Towson, MD 21204
Criminal, DUI and Medical Malpractice
Ross Mailman
Claimed Lawyer Profile
Towson, MD Criminal Law Attorney
(410) 952-8268 17 W. Pennsylvania Avenue
Suite 510
Towson, MD 21204
Criminal, DUI, Estate Planning and Family
Towson, MD Criminal Law Lawyer with 36 years experience
(410) 825-1900 28 Allegheny Ave
Towson, MD 21204
Criminal, Bankruptcy, Consumer and DUI
Towson, MD Criminal Law Lawyer with 17 years experience
(443) 921-1100 300 E Joppa Rd
Towson, MD 21286
Criminal and DUI
Towson, MD Criminal Law Attorney with 15 years experience
(410) 433-3972 1 Olympic Place?Suite 900
Towson, MD 21204
Criminal, DUI, Divorce and Family
Towson, MD Criminal Law Attorney with 20 years experience
(410) 321-8860 220 Bosley Ave
Towson, MD 21204
Criminal, Business, DUI and Divorce
Towson, MD Criminal Law Lawyer
(410) 832-8865 100 West Road
Suite 300
Towson, MD 21204
Criminal, Elder, Estate Planning and Real Estate
University of Maryland School of Law
Judson R. Arnold
PREMIUM

Maryland Criminal Law Attorney

Judson Arnold is an associate in the Silverman, Thompson, Slutkin & White's Criminal Defense practice, litigating in both Federal and State courts. Mr. Arnold also works in conjunction with the Firm's Business... Read More »
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Kathleen Hanlon Sinclair
PREMIUM

Free Consultation! Knowledgeable & Successful Criminal Defense Attorney!

I am an aggressive and accomplished criminal defense lawyer. I fight to protect the rights and interests of the criminally accused! Visit my website for case settlements and verdicts, or call for a free consultation. Read More »
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Mr. G Randolph Rice Jr.
Claimed Lawyer ProfileBlawgsearchSocial Media
Baltimore, MD Criminal Law Lawyer with 12 years experience
(800) 470-7423 6914 Holabird Avenue
Suite A
Baltimore, MD 21222
Free ConsultationCriminal, DUI, Medical Malpractice and Personal Injury
Loyola University New Orleans
The Law Offices of Randolph Rice provides experienced and trusted legal knowledge and advise to individuals and businesses in the Baltimore Maryland region. Concentrating in the areas of Criminal Defense, DUI/DWI, Personal Injury, Injury Law, Medical Malpractice, Wills, Estates, Domestic Matters. Providing personal service to each client. Handling Drug Crimes, Assault Crimes, Domestic Violence, Driving Violations, Traffic Citations, and all other criminal and traffic charges.
Scott Scherr
Claimed Lawyer Profile
Lutherville, MD Criminal Law Attorney with 30 years experience
(410) 821-2910 1407 York Road
Suite 300
Lutherville, MD 21093
Criminal, DUI, Divorce and Personal Injury
University of Maryland Francis King Carey School of Law
I handle a variety of personal injury, automobile accident, workers'compensation, and other related cases as well as serious traffic and criminal matters. My law partner handles divorce and custody cases.
Hasson Barnes
Claimed Lawyer ProfileSocial Media
Baltimore, MD Criminal Law Attorney with 12 years experience
(443) 423-0548 1330 Smith Ave
Suite 200
Baltimore, MD 21209
Criminal, Arbitration & Mediation, Divorce and Family
American University Washington College of Law
Attorney Hasson Barnes practices in the areas of civil and criminal litigation, with a focus on the following areas: Real Estate, Landlord Tenant, Contract Disputes, Criminal Defense, and Family Law. Attorney Barnes also prepares Wills, Power of Attorneys, Deeds, and Health Care Directives, and has extensive experience as a mediator.
Seth Okin
Claimed Lawyer ProfileSocial Media
Lutherville-Timonium, MD Criminal Law Lawyer
(410) 782-0742 108 W Timonium Rd
#333
Lutherville-Timonium, MD 21093
Criminal and DUI
University of Baltimore School of Law
Seth R. Okin is a criminal attorney in Maryland with experience across a wide array of cases ranging from simple traffic charges to serious felonies. Mr. Okin prides himself on building a personalized defense for every person he represents, and is always fighting for the best possible outcome for his clients. Additionally, Mr. Okin is certified in family law and has taken on a number of pro bono cases. Okin is a member of the Maryland State Bar Association, the Baltimore County Bar Association, the Maryland Criminal Defense Attorney's Association, and the American Bar Association. Contact Seth Okin today to...
Grant A. Posner
Claimed Lawyer ProfileLII SilverBlawgsearch
Timonium, MD Criminal Law Lawyer with 10 years experience
(410) 252-0600 108 W Timonium Rd
#303
Timonium, MD 21093
Free ConsultationCriminal, Business, Family and Personal Injury
University of Baltimore School of Law
Jason Plotkin
Claimed Lawyer ProfileSocial Media
Baltimore, MD Criminal Law Attorney with 13 years experience
(410) 661-9440 7602 Harford Rd
Baltimore, MD 21234
Criminal, Bankruptcy, Business and Personal Injury
Jason Plotkin joined the Pinder Legal Team in 2012. He also teaches Business Law at Howard Community College in Columbia, Maryland. Prior to joining the Pinder Legal Team, Jason spent two years investigating Insider Trading in the Office of Fraud Detection and Market Intelligence at the Financial Industry Regulatory Authority (FINRA). Prior to joining FINRA, he spent four years at a law firm representing broker-dealer clients in connection with public and private securities offerings. Jason is a former Judicial Extern for the Honorable Stephen D. Gerling of the United States Bankruptcy Court, Northern District of New York. He is also a former...
Thomas Joseph Maronick Jr
Claimed Lawyer ProfileQ&ALII GoldSocial Media
Baltimore, MD Criminal Law Lawyer with 11 years experience
(410) 244-5068 201 N Charles St.
Suite 2000
Baltimore, MD 21201
Free ConsultationCriminal, DUI, Divorce and Personal Injury
University of Baltimore School of Law
Thomas Maronick Jr is a Super Lawyers-rated attorney who has been practicing since 2008. A Baltimore native, Mr. Maronick is the founder and managing partner of The Law Office of Thomas Maronick Jr, LLC. Mr. Maronick focuses his practice on criminal defense including DUI defense and handles serious felony cases in state and federal court as well as misdemeanors. He has litigated cases in nearly all of Maryland's counties and federal courthouses. Since becoming a lawyer, Mr. Maronick has been honored with "Superb" ratings from Avvo.com, A+ from BBB, "AV-preeminent from Martindale-Hubbell, their highest rating, and being...
Jobeth Rocky Bowers
Claimed Lawyer ProfileQ&ASocial Media
Baltimore, MD Criminal Law Lawyer with 4 years experience
(410) 885-6200 339 E 25th St
Baltimore, MD 21218
Free ConsultationCriminal, Insurance Claims, Personal Injury and Traffic Tickets
University of Baltimore School of Law
I run a client centered practice handling cases in personal injury (worker's compensation and auto accidents) and criminal defense (crimes, serious traffic offenses) I take pride in the results that I provide with my clients, as well as the ongoing communication I maintain with my clients in order to better prepare their cases and claims.
Eric Todd Kirk
Claimed Lawyer ProfileQ&ASocial Media
(410) 591-2835 1001 N. Calvert
Baltimore, MD 21202
Free ConsultationBaltimore, MD Criminal Law Attorney with 25 years experience
Criminal, Personal Injury and Workers' Comp
Albany Law School
I am a Personal Injury Attorney, a Workers' Compensation Lawyer and a Criminal Defense Counselor. Over the course of 20 plus years, I have handled thousands of cases involving accidental injury including hundreds of car accident cases in which my clients have sustained serious personal injury, incurred huge medical bills and lost wages, and were caused to suffer from pain and endure mental anguish. I proudly handle cases throughout Maryland, focusing in Baltimore, Baltimore County, Towson, Essex, Dundalk, Middle River, Parkville, Owings Mills, Randalstown, Pikesville, Ellicot, Anne Arundel County, Glen Burnie, Annapolis, Howard County, or Columbia, Ellicot CIty,...
Benjamin Herbst
Claimed Lawyer ProfileLII GoldBlawgsearchSocial Media
(410) 207-2598 400 E Pratt St
8th Floor
Baltimore, MD 21202
Free ConsultationBaltimore, MD Criminal Law Attorney
Criminal, DUI, Juvenile and Personal Injury
University of Miami School of Law
Benjamin is licensed to practice in all Maryland state and federal jurisdictions, and accepts cases in all counties and in Baltimore City. He has represented well over 1,000 clients in cases ranging from DUI to murder, and has extensive jury trial experience. He has secured acquittals at trial for traffic offenses, drug felonies and violent crimes punishable by life in prison. Benjamin will take on the government in any type of criminal case including drug crimes, firearm offenses, theft, assault, juvenile crimes, cases with outstanding arrest warrants and violations of probation Benjamin is available to his...
Richard M. Karceski
PREMIUM

Free Consultation! Aggressive Lawyer! Experienced Criminal Defense Advocacy!

I am a dedicated and successful criminal defense attorney. I have the experience needed to obtain the best possible outcome in your case. Visit my website for past results and information. Call for a free consultation. Read More »
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Andrew Norman
PREMIUM

Free Consultation! Former Prosecutor! Skilled Criminal Defense Attorney!

With over 30 years of legal experience as a prosecutor, I provide exceptional representation for the accused. I will aggressively defend your rights! Visit my website for case results or call for a free consultation. Read More »
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Alexander Williams Jr.
Claimed Lawyer ProfileLII GoldBlawgsearchSocial Media
Baltimore, MD Criminal Law Lawyer with 46 years experience
(800) 385-2243 201 N Charles St
26th Floor
Baltimore, MD 21201
Free ConsultationCriminal, Business, Civil Rights and White Collar Crime
University of Baltimore School of Law
The Honorable Judge Williams (retired) focuses his practice on complex civil litigation and federal criminal cases. With extensive experience presiding over thousands of complex civil litigation and federal criminal cases Judge Williams is the only practicing retired Federal Judge in Maryland to advise clients on these matters.

The Honorable Judge Alexander Williams, retired from the United States District Court for the District of Maryland on January 3, 2014. He has written over 7 volumes of published opinions and has presided over 6,000 complex civil and 1,000 federal criminal cases.

Prior to his appointment to the federal bench by President Clinton...
Maximillian F. Van Orden, Esq.
Claimed Lawyer ProfileSocial Media
Baltimore, MD Criminal Law Attorney with 23 years experience
(800) 547-4529 923 N. Calvert Street
Baltimore, MD 21202
Free ConsultationCriminal, Bankruptcy, Social Security Disability and Workers' Comp
University of Maryland - Baltimore
Max Van Orden graduated magna cum laude with a Bachelor of Arts degree in Government and Politics from the University of Maryland, College Park in 1992. He received his law degree from the University of Maryland School of Law in 1995, passed the Maryland Bar in December of that same year, and has been practicing law exclusively in the state of Maryland ever since. Mr. Van Orden regularly represents individual clients before the United States Bankruptcy Court for the District of Maryland, the Social Security Administration, the Workers’ Compensation Commission, and the District and Circuit Courts of Maryland. Currently, Mr....
Joseph F. Murphy Jr
Claimed Lawyer ProfileLII GoldBlawgsearchSocial Media
Baltimore, MD Criminal Law Lawyer with 50 years experience
(800) 385-2243 201 N Charles St
26th Floor
Baltimore, MD 21201
Free ConsultationCriminal, Appeals, DUI and White Collar Crime
University of Maryland Francis King Carey School of Law
William Sinclair
Claimed Lawyer ProfileBlawgsearchSocial Media
Baltimore, MD Criminal Law Attorney
(800) 385-2243 201 N Charles St
26th Floor
Baltimore, MD 21201
Free ConsultationCriminal, Business, Personal Injury and White Collar Crime
University of Virginia School of Law
Steven D. Silverman
Claimed Lawyer ProfileLII GoldBlawgsearchSocial Media
Baltimore, MD Criminal Law Attorney with 28 years experience
(800) 385-2243 201 N Charles St
26th Floor
Baltimore, MD 21201
Free ConsultationCriminal, Appeals, DUI and White Collar Crime
University of Baltimore School of Law
Sharareh B. Hoidra
Claimed Lawyer ProfileSocial Media
Pikesville, MD Criminal Law Attorney with 6 years experience
(443) 660-7513 1777 Reisterstown Rd.
Ste. 385
Pikesville, MD 21208
Criminal, DUI, Immigration and Personal Injury
University of Baltimore School of Law
William R. Schmidt III
Claimed Lawyer ProfileSocial Media
Baltimore, MD Criminal Law Attorney with 44 years experience
(800) 547-4529 923 N. Calvert Street
Baltimore, MD 21202
Free ConsultationCriminal and Personal Injury
University of Maryland Francis King Carey School of Law
Rick Schmidt has extensive experience in virtually all facets of personal injury law and has recovered literally millions of dollars for his clients. Mr. Schmidt holds BA and JD degrees from the University of Maryland and its School of Law. At Maryland Law, he won the American Jurisprudence Award for Equitable Remedies. In the 1980’s, Mr. Schmidt was chosen by Us Magazine as one of the 35 most promising Americans under the age of 35. Since then he has co-authored two books: How To Market Your Law Practice (Aspen Press) and Consumer Revenge (Putman’s). Mr. Schmidt has appeared on over...
Brian G. Thompson
Claimed Lawyer ProfileLII GoldBlawgsearchSocial Media
Baltimore, MD Criminal Law Attorney with 23 years experience
(800) 385-2243 201 N Charles St
26th Floor
Baltimore, MD 21201
Free ConsultationCriminal, Communications, DUI and White Collar Crime
University of Baltimore
Phillip J. Closius
Claimed Lawyer ProfileLII GoldBlawgsearchSocial Media
Baltimore, MD Criminal Law Lawyer with 43 years experience
(800) 385-2243 201 N Charles St
26th Floor
Baltimore, MD 21201
Free ConsultationCriminal, Appeals, Business and DUI
Columbia University
Patrick Shane Preller
Claimed Lawyer ProfileSocial Media
Baltimore, MD Criminal Law Attorney with 20 years experience
(410) 539-0042 16 South Frederick Street
3rd Floor
Baltimore, MD 21202
Free ConsultationCriminal, Animal, DUI and Traffic Tickets
University of Baltimore School of Law
Patrick S. Preller is the managing partner of the firm with over seventeen years of litigation experience in federal and state courts throughout the region. Mr. Preller is recognized as one of the most able trial lawyers in Maryland, and has enjoyed an extraordinary record of success.   In 1998, Mr. Preller graduated with honors from the University of Baltimore School of Law where he served as an associate editor on Law Review. Following graduation, Mr. Preller clerked for the Honorable Maurice W. Baldwin on the Circuit Court of Maryland for Harford County.  He then accepted an appointment as an...
Abby Ticse
PREMIUM

Free Consultation! Exceptional Criminal Defense Lawyer! Dedicated Advocacy!

I provide dedicated legal counsel and advocacy for those facing criminal charges. I am committed to skillfully protecting my clients’ rights and interests!Visit my website for case results,call for a free consultation. Read More »
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Jeffrey Scholnick
PREMIUM

Maryland Criminal Law Attorney with 36 years experience

University of Maryland - BaltimoreMaryland
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Towson Criminal Legal Aid & Pro Bono Services

Women's Law Center of Maryland, Inc.
(410) 321-8761
Towson, MD


House of Ruth Domestic Violence Legal Clinic
(410) 889-7884
Baltimore, MD

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Arrested or facing criminal charges?

Criminal law addresses the government's prosecution of individuals who have been accused of committing a crime. Such laws may be federal, state, or local. The prosecution represents the people of a particular jurisdiction, and acts on behalf of the government by bringing a case against an accused. Under the U.S. Constitution, a person accused of a crime may have the right to a criminal defense attorney during interrogations and certain other times before and during a trial.

Whether you are under police investigation, have been arrested, or are facing charges, having an advocate familiar with the criminal justice system.

Most jurisdictions classify crimes as felonies or misdemeanors, with felonies being the more serious offenses with the possibility of more severe sentences. Some criminal lawyers focus on a specific area of criminal defense law, such as white-collar crime, drug offenses, theft crimes, or violent crimes. You should consult with a criminal defense lawyer early on in the process to preserve options, such as diversion programs or plea bargains.

When hiring a criminal defense attorney, you should evaluate the experience and fee structure of the attorney. Some offer a free consultation to discuss your case.


Accomplice liability: If a person aids, assists, or encourages another in the commission of a crime, they are criminally liable as an accomplice to the crime.

Self-defense: The claim that an act otherwise criminal was legally justifiable because it was necessary to protect a person or property from the threat or action of another.