State v. Ivy

The State of Wisconsin seeks review of a decision reversing a judgment convicting Gerald Collie Ivy, Jr. of aiding and abetting armed robbery, and of aiding and abetting injury by conduct regardless of life.

The court of appeals held that because an armed robbery cannot under any circumstances be a natural and probable consequence of a robbery, a person convicted as an aider and abettor to an armed robbery must have had actual knowledge that the principals would be armed. We hold that, depending on the facts and circumstances of a given case, an armed robbery can be a natural and probable…