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Commonwealth v. Roebuck

32 A.3d 613 (Pa. 2011)

tl;dr: A defendant can be convicted of third degree murder under an accomplice theory of liability so long as it is proven that he had the requisite criminal intent required under the statute.

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The Supreme Court of Pennsylvania ruled on a case where the defendant was charged with third-degree murder as an accomplice. The defendant argued that accomplice liability for third-degree murder is not supported by legal theory because it is an unintentional act. However, the court held that complicity theory applies in third-degree murder cases where intentional acts demonstrate a disregard for human life amounting to malice, even if homicide was not the intended underlying crime. The appellant argues that accomplice liability for third-degree murder is a legal anomaly based on his impossibility syllogism. The appellant cites Section 306 of the Pennsylvania Crimes Code and discusses cases disapproving convictions based on logical and/or legal impossibility. The appellant acknowledges that the accomplice theory is distinct but urges that the same impossibility rationale should apply since aiding in an unintentional crime is logically impossible. The appellant references a disapproved plurality decision of the New Hampshire Supreme Court and a concurring opinion by former Justice Souter of the US Supreme Court. The appellant suggests that an individual cannot be guilty of conspiracy to commit third-degree murder because it requires intending to commit an unintentional killing, which is a logical impossibility. The judgment of sentence was affirmed, and the legal challenge to the application of complicity theory to third-degree murder was resolved.

The Commonwealth argues that accomplice liability applies to third-degree murder, citing Commonwealth v. Kimbrough. The Model Penal Code (MPC) uses complicity theory and defines murder as "recklessness under circumstances manifesting extreme indifference to the value of human life." The MPC recognizes different mental states for each objective element of an offense and distinguishes among these categories in its prescriptions regarding which level of culpability is required for each element. The MPC's treatment of accomplice liability is addressed in Section 2.06, which defines the term "accomplice" and the requisite mens rea for legal accountability of accomplices in the commission of an offense. An accomplice may be held legally accountable if they aid in the conduct and act with recklessness. The essential culpability requirement is provided in subsection 4, which holds the accomplice accountable to the degree of their culpability, which must equal what is required to support liability of a principal actor.

Accomplices can be held criminally liable for recklessness, as supported by the Model Penal Code and Pennsylvania Crimes Code. Attempt and conspiracy have different requirements for mental culpability compared to accomplice liability. Accomplice liability does not require the defendant to have the conscious objective to cause a particular result when such an outcome is an element of the offense. The court held that a defendant can be held liable for a criminally negligent act under complicity theory if they have the required mental state and intentionally aid another in the crime. An accomplice to third degree murder intends to aid a malicious act that results in a killing, not an unintentional murder. Therefore, the appellant is guilty of murder.

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Commonwealth v. Roebuck

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