People v. Zierlion

Four men broke into a commercial building and pushed a heavy safe out a second-floor window into the yard below, then recruited Richard Zierlion (defendant) and one other man to help move it because it was too heavy. Police arrived and a gunfight ensued in which Zierlion was wounded and his fellow recruit killed. Illinois prosecuted Zierlion for burglary itself under a statute making anyone who aids or assists a perpetrator a principal; the trial judge, sitting without a jury, convicted him as a principal, and Zierlion appealed.