People v. Wheeler

ROVIRA, Justice.

The defendant, Laurie Wheeler, was convicted of criminally negligent homicide as the result of a jury trial. The trial court granted her motion for judgment of acquittal, holding that criminally negligent homicide by a complicitor is not a cognizable crime. On appeal, the People argue that the trial court’s ruling was based on a misunderstanding of the complicity theory of accountability. We agree with the People’s position and hold that the trial court erred in entering the judgment of acquittal.

I

The facts necessary for an understanding of the issue in this case are not in…