CRAIG JEROD JACKSON, APPELLANT,
v.
THE STATE OF FLORIDA, APPELLEE
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The court reversed a conviction for aiding and abetting a robbery, finding the evidence insufficient to prove the defendant's prior knowledge or intent to participate in the offense. The opinion highlights the state's failure to charge the defendant with a crime supported by the evidence.
No, the evidence was insufficient to prove that Jackson knew beforehand of his companion's intentions or that he intended to participate in the robbery. Therefore, his conviction for aiding and abetting was not supported.
[1] Evidence that a defendant drove a perpetrator to the scene of a crime, was present when the spoils of the robbery were found, and fled the scene is insufficient to prove…
[2] A conviction for aiding and abetting requires proof that the defendant knew beforehand of the principal's intentions or had a prior intention to participate in the offens…
Previewing 2 of 3 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“Evidence that (a) the victim of a purse snatching, committed by a person other than the defendant, saw Jackson emerging from an automobile which the victim had followed from the vicinity of the scene of the robbery; (b) the spoils of the robbery were found in the automobile occupied by Jackson and the perpetrator of the robbery; and (c) Jackson fled from the scene of the robbery; even if arguably supporting inferences that Jackson had driven the perpetrator to and from the scene and had after-the-fact knowledge of the robbery, is insufficient to prove that Jackson knew beforehand of his companion’s intentions, much less that he had a prior intention to participate in the offense, and manifestly does not support Jackson’s conviction for aiding and abetting in the commission of the robbery.”
Establishes the facts presented and the court's conclusion that they are insufficient for an aiding and abetting conviction.
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Join FLexlaw to unlock all legal intelligenceThe victim of a purse snatching identified Jackson emerging from a car that the victim had followed from the robbery scene. The stolen goods were foun…
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DANIEL S. PEARSON, Judge.
Evidence that (a) the victim of a purse snatching, committed by a person other than the defendant, saw Jackson emerging from an automobile which the victim had followed from the vicinity of the scene of the robbery; (b) the spoils of the robbery were found in the automobile occupied by Jackson and the perpetrator of the robbery; and (c) Jackson fled from the scene of the robbery; even if arguably supporting inferences that Jackson had driven the perpetrator to and from the scene and had after-the-fact knowledge of the robbery, is insufficient to prove that Jackson knew beforehand of his companion’s intentions, much less that he had a prior intention to participate in the offense, and manifestly does not support Jackson’s conviction for aiding and abetting in the commission of the robbery. D.M. v. State, 435 So. 2d 976 (Fla. 3d DCA 1983); Davis v. State, 436 So. 2d 196 (Fla. 4th DCA 1983); Gains v. State, 417 So. 2d 719 (Fla. 1st DCA 1982), rev. den., 426 So. 2d 26 (Fla.1983); Stuckey v. State, 414 So. 2d 1160 (Fla. 3d DCA 1982); A.Y.G. v. State, 414 So. 2d 1158 (Fla. 3d DCA 1982); G.C. v. State, 407 So. 2d 639 (Fla. 3d DCA 1981); J.L.B. v. State, 396 So. 2d 761 (Fla. 3d DCA 1981); Perez v. State, 390 So. 2d 85 (Fla. 3d DCA 1980); J.O. v. State, 384 So. 2d 966 (Fla. 3d DCA 1980); Pack v. State, 381 So. 2d 1199 (Fla. 2d DCA 1980); J.H. v. State, 370 So. 2d 1219 (Fla. 3d DCA 1979), cert. den., 379 So. 2d 209 (Fla.1980); K.W.U. v. State, 367 So. 2d 647 (Fla. 3d DCA), cert. den., 378 So. 2d 349 (Fla.1979).
As this case once again illustrates, the State’s ill-advised decision to charge the defendant with a crime which the evidence will not support and forego charging the defendant with a crime, e.g., accessory after the fact, which the evidence might justify, serves well the interest of the defendant, but hardly the interest of justice or the community. See A.Y.G. v. State, 414 So. 2d at 1159.
Reversed with directions to discharge the defendant.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
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Smith v. State, 502 So. 2d 77 (Fla. 3d DCA 1987)…request, without more, was insufficient to convict as an aider and abettor. We agree. A defendant cannot be convicted of a charged substantive offense based on evidence which proves involvement only as an accessory after the fact. Jackson v. State, 436 So. 2d 1085 (Fla. 3d DCA 1983); A.Y.G. v. State. Likewise probation cannot be revoked where the proof supports only an offense other than the one charged. Brown v. State, 468 So. 2d 439 (Fla. 2d DCA 1985). Nothing in the record excludes the reasonable inference…
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Cannon v. State, 18 So. 3d 562 (Fla. 1st DCA 2009)…bout what had happened. “A defendant cannot be convicted of a charged substantive offense based on evidence which proves involvement only as an accessory after the fact.” Smith v. State, 502 So. 2d 77, 78 (Fla. 3d DCA 1987) (citing Jackson v. State, 436 So. 2d 1085 (Fla. 3d DCA 1983)). "Although Florida has abolished the common law distinctions between principals, aiders and abettors, and accessories before the fact, accessory after the fact remains a separate offense.” Staten v. State, 519 So. 2d 622, 626 (F…
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J.M. v. State, 460 So. 2d 559 (Fla. 3d DCA 1984)…PER CURIAM. We reverse an adjudication of delinquency because of insufficient evidence that the juvenile committed the crime charged in the petition for delinquency. State v. V.D.B., 270 So. 2d 6 (Fla.1972); Jackson v. State, 436 So. 2d 1085 (Fla. 3d DCA 1983); Lockett v. State, 262 So. 2d 253 (Fla. 4th DCA 1972); In Re Winship, 397 U.S. 358, 90 S.Ct. 1068, 25 L.Ed.2d 368 (1970).…
Previewing 3 of 4 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited (13 total)
- J. H. v. State, 370 So. 2d 1219 (Fla. 3d DCA 1979)
- Pack v. State, 381 So. 2d 1199 (Fla. 2d DCA 1980)
- Gains v. State, 417 So. 2d 719 (Fla. 1st DCA 1982)
- G. C. v. State, 407 So. 2d 639 (Fla. 3d DCA 1981)
- J. L. B. v. State, 396 So. 2d 761 (Fla. 3d DCA 1981)
- A. Y. G. v. State, 414 So. 2d 1158 (Fla. 3d DCA 1982)
- J. O. and R. G. v. State, 384 So. 2d 966 (Fla. 3d DCA 1980)
- K. W. U. v. State, 367 So. 2d 647 (Fla. 3d DCA 1979)
- Francis v. State, 436 So. 2d 196 (Fla. 2d DCA 1983)
- Rook v. Allstate Ins. Co., 436 So. 2d 196 (Fla. 2d DCA 1983)