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Supreme Court of Pennsylvania - 32 A.3d 613
Tags: Criminal law, Accomplice liability
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.Video Summary
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The case concerns whether accomplice liability can be applied to third-degree murder. The intermediate court held that accomplice theory applies in third-degree murder scenarios where the intentional acts demonstrate a disregard for human life amounting to malice, even if homicide was not the intended underlying crime. The defendant argues that accomplice liability for third-degree murder is a legal anomaly due to his impossibility syllogism. The defendant cites a series of Superior Court opinions and decisions from other jurisdictions that disapprove convictions based on logical and/or legal impossibility. The Appellant argues that conspiracy to commit third-degree murder is impossible because it requires intending to commit an unintentional killing. The Commonwealth argues that accomplice liability applies to third-degree murder, as the shared criminal intent behind the conduct establishes criminal culpability. The American Law Institute's Model Penal Code (MPC) was designed to establish legal accountability for an accomplice for unintended results caused by a principal.
The statement clarifies that an individual may be held responsible for being an accomplice to third-degree murder even if they had no intention to kill. Third-degree murder does not require a specific intent but involves a malicious act resulting in death. An individual may be held liable if they help or encourage another person who knowingly disregards a significant risk of death. The legal theory applied in the Kimbrough case was appropriate and reasonable, as per the Chief Justice's agreement.
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