People v. Scott

Summary

The New York Appellate Division, Fourth Department reversed Randall A. Scott’s murder conviction and dismissed the indictment. The court held that the evidence was legally insufficient to establish that Scott, who transported the shooter, shared the shooter’s intent to kill, and alternatively concluded that the verdict was against the weight of the evidence.

Holdings

1. The evidence was legally insufficient to establish that defendant shared the codefendant's intent to kill the victim, an essential element of accessorial liability for intentional murder.
2. Even assuming the evidence was legally sufficient, the verdict was against the weight of the evidence because the People failed to prove beyond a reasonable doubt that defendant shared the codefendant's intent to kill.

Questions Presented

1. Whether the evidence was legally sufficient to establish that defendant, as an accessory, shared the codefendant's intent to kill and intentionally aided the commission of second-degree murder.
2. Whether the verdict was against the weight of the evidence because the People failed to prove beyond a reasonable doubt that defendant shared the codefendant's intent to kill.

Disposition

reversed_and_remanded