Franchie Farmer v. United States

SYKES, Circuit Judge.

In 2012 a jury convicted Franchie Farmer of armed bank robbery, see 18 U.S.C. § 2113(a) and (d), and brandishing a firearm during a crime of violence, see id. § 924(e)(l)(A)(ii). Farmer drove the getaway car and was not in the bank during the robbery. Her convictions were thus premised on an accomplice theory of liability as an aider or abettor under 18 U.S.C. § 2.

In 2014 the Supreme Court held that a § 924(c) conviction under an accomplice theory requires proof that the accomplice had “foreknowledge that his confederate [would] commit the offense with a firearm.”…