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Law School Case Briefs

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Roy v. United States

District of Columbia Court of Appeals (1995) | 652 A.2d 1098; 1995 D.C. App. LEXIS 6; 1995 WL 21120

3 min read

TL;DR: An accomplice who intended to aid an illegal gun sale cannot be convicted of an armed robbery committed by the principal, as the robbery was not a "natural and probable consequence" of the planned sale. The court reversed the accomplice's robbery conviction.

Legal Significance: This case significantly narrows the "natural and probable consequences" doctrine of accomplice liability, requiring more than mere foreseeability and distinguishing between the intended crime and a "qualitatively different" offense committed by the principal.

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