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Vaden v. State

768 P.2d 1102 (1989)

tl;dr: The public authority justification available to an undercover agent acting as the principal does not impute to the accomplice.

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This case involves the appeal of hunting guides, Douglas Vaden and Floyd Saltz Jr., who were convicted of illegal hunting methods and killing foxes during a closed season. Vaden argued that the undercover agent's actions amounted to entrapment and violated due process, but the court of appeals upheld his convictions. The court expressed concern about convicting Vaden as an accessory when the principal was a government agent but found that the defense of entrapment could apply. However, since Vaden failed to show that police conduct induced him to commit the offense, his convictions were upheld. The Supreme Court of Alaska denied a rehearing.

Saltz was charged with killing and wasting caribou and using illegal fishing gear. His pretrial motions to dismiss were denied, and he was convicted on all 16 counts, including soliciting the violations. Saltz appealed his convictions, arguing that they should be reversed due to Pagel's illegal acts. The court rejected this argument but found that some counts violated double jeopardy principles and ordered the trial court to vacate them.

Vaden and Saltz challenged their convictions for aiding and abetting and transportation, arguing that the undercover agent's actions were illegal. The court found that the public authority justification defense is personal to the undercover agent and cannot be transferred to the accomplice. The entrapment defense is not imputed to the accomplice. The court affirms the decision of the court of appeals.

Vaden and Saltz challenge their convictions on due process grounds, citing cases where government conduct in drug sales or manufacture was found to be outrageous enough to warrant dismissal. However, the court finds that the conduct of the undercover agents in this case did not violate due process. Judge Singleton agreed that Snell's actions were illegal but disagreed with the court's suggestion that the entrapment defense alone was enough to protect against government overreaching. Chief Judge Bryner dissented, stating that the state's conduct fell below an acceptable standard for the fair administration of justice and justified dismissal of the charges against Vaden.

The court upholds the convictions of Vaden and Saltz, stating that the government's conduct was not severe enough to warrant dismissal of charges. Justices Burke and Moore dissent, arguing that the defendants' convictions should be quashed because the criminal act that serves as the basis for the charges was supplied by government agents. The court finds that the government's conduct in this case was outrageous enough to warrant dismissal of charges. The court upholds convictions based on independent criminal acts but reverses those based on accomplice liability and transportation of illegally taken game charges. These convictions violate due process principles and fall within the parameters of the due process/outrageous conduct defense.

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IRACIssue, Rule, Analysis, Conclusion

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Facts & Holding

Facts:Vaden worked as a hunting guide in Alaska. It was...

Holding:Vaden was properly convicted, because the public authority justification that...

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Vaden v. State

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