Pennsylvania v. Potts
Supreme Court of Pennsylvania
566 A.2d 287 (1989)
After learning Michael Cunerd had burglarized his home, Ernest Potts (defendant), accompanied by armed companion David Owens, drove Cunerd to a deserted area to question and confront him; when Cunerd denied involvement and a brief fight ensued between Potts and Cunerd, Owens chased down the fleeing Cunerd and fatally stabbed him while Potts watched from about 30 feet away, then told Owens to search the body's pockets before both men fled. Potts admitted knowing Owens was armed beforehand, and a witness testified Potts had said two days before the murder that he intended to kill Cunerd; Potts was convicted as an accomplice to first-degree murder and appealed, arguing he only intended to physically assault Cunerd, not facilitate his killing.
Whether sufficient evidence supported a conviction for accomplice liability to murder where the defendant claimed he intended only a physical assault on the victim, not to facilitate the killing itself.