United States v. Peoni

Brief Fact Summary.

Peoni appealed an accessory liability charge after a person to whom he sold counterfeit money sold the counterfeit dollar bills to another party

Synopsis of Rule of Law.

An individual cannot be charged as an accessory to a crime that they had no knowledge was committed.

Facts.

Peoni sold counterfeit dollar bills to Regno, who sold counterfeit dollar bills to Dorsey. Peoni was convicted on three counts of possession of counterfeit money, with the last two counts labeling Peoni as an accessory to Regno and Dorsey. Peoni appealed his accessory liability for Dorsey’s possession charge

Issue.

Whether an individual can be charged as an accessory to a crime that they had no knowledge was committed?

Held.

No. Peoni’s conviction is reversed. Peoni did not know that Regno sold the counterfeit dollar bills to Dorsey. In order for Peoni to be held liable as an accessory to Dorsey’s possession, Dorsey would need to know or have reason to know that Dorsey possessed the counterfeit bills.

Discussion.

Anyone who aids in the commission of a crime can be charged as a principal to that crime. The person being charged as the principal of that crime has to know that the crime is being committed in order to be convicted as a principal to the crime.