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State v. Foster

Supreme Court of Connecticut
202 Conn. 520 (1987)
ELI5:

Rule of Law:

A person can be criminally liable as an accessory to a crime requiring a negligent mental state, such as criminally negligent homicide, if they intentionally aid the principal while possessing the mental culpability required for the commission of the underlying offense.


Facts:

  • The girlfriend of Michael Foster was robbed and raped by a man who held a straight-edged razor to her throat.
  • Foster's girlfriend described the attacker and his specific identifiable features to Foster.
  • Bitter about the attack, Foster and his friend, Otha Cannon, went looking for the assailant.
  • Foster identified William Jack Middleton as the attacker, and a fight ensued in which Foster beat Middleton with his fists and a blunt instrument.
  • Foster told Middleton to wait at the scene while he left to get his girlfriend to make an identification.
  • Suspecting Middleton might flee, Foster gave Cannon a knife and instructed him to stay with Middleton to prevent his escape.
  • While Foster was away, Middleton charged at Cannon, who then held out the knife and fatally stabbed Middleton.

Procedural Posture:

  • Michael Foster was charged by information with multiple counts, including manslaughter and being an accessory to manslaughter.
  • The trial court granted Foster's motion to dismiss a charge of hindering prosecution.
  • At the close of the state's case, the trial court granted Foster's motion for a judgment of acquittal on a charge of carrying a dangerous weapon.
  • The jury found Foster guilty of kidnapping, assault in the third degree (as a lesser included offense), and being an accessory to criminally negligent homicide (as a lesser included offense of being an accessory to manslaughter).
  • Foster filed post-trial motions for acquittal and in arrest of judgment, arguing that being an accessory to criminally negligent homicide is not a legally recognized crime.
  • The trial court denied Foster's post-trial motions and imposed a sentence.
  • Foster appealed his convictions to the Supreme Court of Connecticut.

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Issue:

Is being an accessory to criminally negligent homicide a legally cognizable crime under Connecticut law, despite the offense requiring an unintended result?


Opinions:

Majority - Santaniello, J.

Yes, being an accessory to criminally negligent homicide is a cognizable crime. Unlike attempt or conspiracy, accessorial liability does not require the specific intent to cause the criminal result; it only requires that the defendant (1) intentionally aids another person and (2) acts with the mental state required for the commission of the underlying offense. Accessorial liability is not a distinct crime but merely an alternative means of committing a substantive offense. Therefore, it is not a logical impossibility to be an accessory to a crime of negligence, as one can intentionally aid another while failing to perceive a substantial and unjustifiable risk of death, which is the mental state for criminally negligent homicide. The court distinguished this from attempt and conspiracy, which are inchoate crimes that require the specific intent to bring about the prohibited result, making it logically impossible to attempt or conspire to cause an unintended result.



Analysis:

This decision significantly clarifies the scope of accessorial liability by distinguishing it from inchoate offenses like attempt and conspiracy. The court establishes that the 'dual intent' requirement for accomplices does not mean the accessory must intend the specific result of the crime, but rather that they must intend to aid the principal and possess the requisite mental state for the underlying crime, whether it be intent, recklessness, or negligence. This broadens the application of accomplice liability to crimes involving unintended results, ensuring that individuals who intentionally assist in dangerous conduct can be held responsible for foreseeable, albeit unintended, criminal outcomes. This ruling reinforces the principle that an accessory's liability is measured by their own mental culpability in relation to the crime committed.

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