State v. Coleman

An informant arranged to buy drugs from Sean Phillips while police watched nearby. After the deal, Phillips ran back to a car that had dropped him off, and when police chased the car, it sped away; officers later found the car abandoned with Coleman (defendant) walking away from it. Phillips, who pleaded guilty and testified against Coleman, said Coleman had obtained a gun and agreed the day before to pick Phillips up after Phillips robbed the informant. The trial judge told the jury Coleman was guilty as an accomplice if, knowing his conduct would further the crime, he agreed to aid in planning or committing it, and that acting with knowledge could be shown by proof he acted intentionally. The jury convicted Coleman, who appealed, arguing the instruction improperly blurred the required act with the required mental state and did not demand proof of any actual assisting act.