Hawaii v. Soares

A store detective saw Ronald Soares (defendant) and Hollie Suratt load cigarette cartons into a shopping cart and then into a handbag before leaving the store without paying; when confronted, they fled with the merchandise. The trial court's jury instruction stated that anyone present and participating in a crime was responsible for acts of others done in furtherance of it, without separately requiring proof that Soares intended to promote or facilitate the theft. The jury convicted Soares as an accomplice.