Baker v. Alaska

Donald Baker (defendant) and two friends plotted to rob a pizza deliveryman by ordering pizzas to a fake address and ambushing him; when the deliveryman couldn't find the address and turned to leave, one of the three hit him repeatedly, the group grabbed the dropped pizzas, and all three fled, though the deliveryman could not identify which man had struck him. At trial the prosecution's theory was that Baker was the one who hit the victim, and it told the jury Baker could be convicted even without that specific belief, so long as jurors believed Baker was one of the three robbers; the judge then instructed the jury on accomplice liability. Baker was convicted and appealed, arguing the accomplice instruction improperly let him be convicted as an accessory despite being charged as a principal, and that the indictment failed to give him fair notice of that possibility.