State v. Davis

Petitioner Michael C. Davis appeals a Court of Appeals decision reversing the trial judge's decision to grant petitioner's motion for a new trial. The case presents an issue of first impression for this court: Where criminal liability for a first degree robbery is premised upon accomplice liability, must the State prove that the accomplice knew the principal was armed?

After reviewing both the statutes and authority from states with similar legislative schemes, we find that the State is not required to prove that the accomplice had knowledge that the principal was armed. We affirm the decision…