Law School Case Brief
State v. Bridges - 133 N.J. 447, 628 A.2d 270 (1993)
Conspirators are liable for the criminal acts of their co-conspirators that follow incidentally in the execution of the common design as one of its probable and natural consequences.
Defendant Bennie Eugene Bridges was convicted by a jury of conspiracy and several substantive crimes, including murder, which were committed in the course of carrying out the conspiracy. On appeal the Appellate Division, with a dissent, ruled that the liability of a co-conspirator for the commission of substantive crimes, like accomplice liability, requires specific intent to commit those crimes. On that ground it affirmed the conspiracy conviction but reversed the substantive criminal convictions. The dissent concluded that a conspirator can be vicariously liable for the substantive crimes of co-conspirators without the specific mental state otherwise required of those crimes, provided that their commission of those crimes was foreseeable as a natural consequence of the conspiracy.
Was Bridges’ conviction of conspiracy and several substantive crimes, including murder, which were committed in the course of carrying out the conspiracy but were not within the scope of the original conspiracy, proper?
In reviewing the previous court's reversal of most of the charges against Bridges other than conspiracy, the court held that a co-conspirator may be liable for the commission of substantive criminal acts that were not within the scope of the conspiracy if they were reasonably foreseeable as natural consequences of it. The court remanded for reconsidering whether the commission of the substantive crime was actually beyond the scope of the original conspiracy, and if so, whether it was reasonably anticipated that the substantive crime would be committed, or whether it was too far removed from the objectives of the original conspiracy; which did not have as its objective the purposeful killing of another person. The court affirmed the conviction for conspiracy, finding that a jury could conclude that a reasonably foreseeable risk and a probable and natural consequence of carrying out a plan to intimidate a crowd by using loaded guns would be that someone would intentionally fire at the crowd, and that act would be sufficiently connected to the original conspiratorial plan to provide a just basis for a determination of guilt for that substantive crime.
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