State v. Linscott
Supreme Judicial Court of Maine
520 A.2d 1067 (1987)
William Linscott (defendant) and his friend Joel Fuller planned to rob drug dealer Norman Grenier, agreeing to break a window and display their gun to discourage resistance without actually using it. At Grenier's home, Linscott broke the window as planned, but instead of merely showing the gun, Fuller immediately fired through the broken window, killing Grenier; Fuller then took $1,300 from Grenier's pocket and left. At trial Linscott testified he never intended for Grenier to die. The trial court convicted him of robbery outright and convicted him of murder as an accomplice, reasoning Grenier's death was a natural and probable consequence of the robbery he had agreed to help commit. Linscott appealed.
Whether the natural-and-probable-consequence doctrine of accomplice liability violates the Fourteenth Amendment's Due Process Clause.