Lane v. Texas
Court of Appeals of Texas
991 S.W.2d 904 (1999)
Lane (defendant) planned and drove friends, including Patricia, to rob an elderly man, staying in the car with Patricia while two others carried out the robbery, encouraging them to go through with it after an initial abandoned attempt; the trial court instructed the jury that two of the participants were accomplices requiring corroboration, but refused to give the same instruction as to Patricia, whose testimony was then used to corroborate the others. Lane, convicted, appealed the refusal to instruct the jury that Patricia was also an accomplice.
Whether, under Texas law, an individual is an accomplice to a crime if he or she does not perform an affirmative act or omission in furtherance of the crime.