Citation. Pa. Sup. Ct. 32 A.3d 613 (2011)
Law Students: Don’t know your Studybuddy Pro login? Register here Brief Fact Summary.
Roebuck (D) was found guilty of luring the victim to an apartment complex where the victim was shot and killed by another person.
Synopsis of Rule of Law.
A person is an accomplice if he/she acts with the level of culpability that equals the level required to support criminal liability by the principal actor in a situation whereby a particular result is caused as an element of an offense.
Facts.
Roebuck (D) assisted in luring a victim to an apartment complex where the victim was eventually shot and killed. Although Roebuck (D) did not pull the trigger, he was charged as an accomplice to third-degree murder. Roebuck (D) appealed the ruling of the trial court which found him guilty on the ground that accomplice liability required an intent element, and since third-degree murder is defined as an unintentional killing, accomplice liability could not attach to the crime.
Issue.
Is a person who acts with the level of culpability that equals the level required to support criminal liability by the principal actor in a situation whereby a particular result is caused as an element of an offense an accomplice?
Held.
(Saylor, J.) Yes. A person is an accomplice if he/she acts with the level of culpability that equals the level required to support criminal liability by the principal actor in a situation whereby a particular result is caused as an element of an offense. An accomplice is defined by the Model Penal Code 2.06 (3) as a person with the purpose of promoting or facilitating the commission of the offense by the principal actor. The Code also defines an accomplice as a person who aids or attempts to aid the principal actor in planning or committing the offense. A court need only establish that Roebuck (D) participated in the events which lead to the victim’s death. Hence, the lower court found sufficient evidence to support its verdict and the ruling is thus sustained.
Concurrence.
(Eakin, J.) Roebuck’s (D) argument is wrong because an accomplice to a third-degree murder has the intention to aid a malicious act that results in a killing. Hence, the logic that enables a murder charge against the principal actor also applies to the accomplice as well.
Discussion.
An accomplice may be found guilty when he acts recklessly as opposed to intentionally. This is the significance of this ruling.
