United States v. Simpson
United States Court of Appeals for the Eighth Circuit
979 F.2d 1282 (1992)
Sharon Simpson (defendant) helped her boyfriend Mark Grotte plan and escape from an armed bank robbery, driving the getaway car and helping conceal his gun and the stolen cash, and was convicted of aiding and abetting both the armed robbery and Grotte's use of a firearm during that crime after refusing to testify against him. The sentencing judge reduced her sentence on the robbery count given her minor role but imposed the firearm statute's mandatory consecutive five-year minimum on the second count, and Simpson appealed, arguing the aiding-and-abetting statute allowed sentencing discretion that should have let the judge avoid the mandatory minimum.
Whether a defendant convicted of aiding and abetting a firearm offense during a crime of violence is subject to that offense's mandatory minimum sentence, or whether the aiding-and-abetting statute independently provides sentencing discretion to avoid it.