Brief Fact Summary. The Defendant, William Linscott (Defendant), appeals from a judgment following a jury-waived trial convicting him of one count of murder and one count of robbery. The Defendant contends that his conviction of intentional or knowing murder as an accomplice under the applicable accomplice liability statute violated his constitutional right to due process of law in that he lacked the requisite intent to commit murder.
Synopsis of Rule of Law. Accomplice liability for a primary crime (i.e. robbery) is established by proof that the actor intended to promote or facilitate that crime. Liability for a secondary crime (i.e. murder) that may have been committed by the principal is established upon a two-part showing: (1) that the actor intended to promote the primary crime and (2) that the commission of the secondary crime was a “foreseeable consequence” of the actor’s participation in the primary crime.
Issue. Whether the Defendant’s conviction, pursuant to the applicable accomplice liability statute, unconstitutionally violated his right to due process under Article I of the Maine Constitution and the Fourteenth Amendment of the United States Constitution (Constitution)?
Held. The Supreme Judicial Court of Maine finds no constitutional defect in the statutory provision assigning liability to the Defendant as an accomplice in this matter. Furthermore, there is no fundamental unfairness in the application of the relevant statutory provision.
Discussion. The court noted that they have consistently upheld application of the accomplice liability statute as it pertains to reasonably foreseeable consequences. Further, the court stated that life imprisonment for murder under an accomplice liability theory is not so severe as to shock the conscious. Therefore, due to the statute’s historical application and due to its reasonable punishment, the conviction was upheld and not deemed to be in violation of the Defendant’s constitutional rights.