State v. Parker
Supreme Court of Minnesota
164 N.W.2d 633 (1969)
Larry Leventhal gave John Parker (defendant) and two other passengers a ride; the passengers robbed and severely beat Leventhal and stole his wallet, watch, and car. Parker and the others were later pulled over driving Leventhal's car and were arrested after attempting to flee on foot. At trial, Leventhal testified Parker personally participated in the robbery and assault, while Parker claimed he merely watched without participating. The jury, after requesting further instruction on aiding and abetting, convicted Parker, and he appealed, arguing the instructions effectively imposed a legal duty on him to help Leventhal that he did not actually have.
Whether a defendant may be found guilty of aiding or abetting a crime without actively participating in the overt criminal act.