New Jersey v. Hughes
Superior Court of New Jersey, Appellate Division
521 A.2d 1295 (1986)
Two men robbed a cashier at gunpoint at a newspaper office. New Jersey (plaintiff) charged Thomas Hughes (defendant) with robbery, unlawful weapon possession, and conspiracy to rob. At trial, Hughes testified that Tyrone Wolley had repeatedly approached him about joining the robbery beforehand and that he refused each time; a police detective confirmed Hughes had told police about Wolley's recruitment attempts and his own refusals. Hughes requested a jury instruction on the renunciation-of-purpose defense, which the trial judge denied. The jury convicted Hughes of conspiracy and deadlocked on the other two charges, and Hughes appealed the denial of the instruction.
Whether the renunciation-of-purpose defense to a conspiracy charge requires proof that the defendant informed authorities of his own participation in the conspiracy, rather than merely reporting another person's recruitment attempts.