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Roy v. United States

(1995)

District of Columbia Court of Appeals - 652 A.2d 1098

tl;dr:

An accomplice cannot be held liable for a crime that was not a reasonably foreseeable consequence of the conspiracy.

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ICRAIssue, Conclusion, Rule, Analysis for Roy v. United States

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Facts & HoldingRoy v. United States case brief facts & holding

Facts:Roy agreed to sell a gun to a government informant...

Holding:The court held that he could not be held liable...

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Roy v. United States | Case Brief DeepDive
Majority opinion, author: SCHWELB, Associate Judge:
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Nakia A. Roy and Steve B. Ross were convicted of armed robbery, possession of a firearm during the commission of a crime of violence, and carrying a pistol without a license. Ross was also convicted of obstruction of justice. Roy appealed, alleging instructional error, and Ross claimed that the judge erred in denying his motion to sever offenses. The court found that the evidence was insufficient to support Roy's convictions of armed robbery and possession of a firearm during the commission of a crime of violence, but affirmed his conviction for carrying a pistol without a license and all of Ross's convictions. The trial judge expressed doubts about the extent of liability under Theory B, which holds Roy vicariously liable for the armed robbery if it was a natural and probable consequence of his aiding and abetting the illegal act of selling a gun. The judge recognized the need to balance the principle of aiding and abetting with the requirement of mens rea for a criminal offense. The judge believes that the alternative doctrine of aiding and abetting, which the government is relying on in Roy's case, is supported by case law but needs to be re-examined by the Court of Appeals. The District of Columbia Court of Appeals is reviewing the trial judge's denial of Roy's motion for judgment of acquittal.

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Roy v. United States

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