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accomplice liability

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Ninth Circuit Finds that Washington Accomplice Liability Matches Federal Definition

The Ninth Circuit has determined that both Washington and federal generic accomplice liability law require prosecutors to meet the same standard of proof: they must show the accomplice had advance knowledge of the crime he facilitated. In so holding, the court overruled US v. Valdivia-Flores and US v. Franklin and held that second-degree robbery in Washington matches the definition of a theft aggravated felony.

The full text of Alfred v. Garland (including two concurrences and two dissents):

https://cdn.ca9.uscourts.gov/datastore/opinions/2023/03/30/19-72903.pdf

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