State v. Carson

Jubal Carson (defendant) planned and initiated a robbery of a television-repair shop. Carson recruited two accomplices for the crime, Aaron Gary and Alton Stover (defendants). Carson described the layout of the shop to them, gave them guns, and drove them to the shop. Carson waited in the car while Gary and Stover entered the shop, tied up two employees at gunpoint, stole money, and fired three shots through a closed door toward the employees. Unbeknownst to any of the robbers, however, the shop was the subject of an undercover sting operation being run by the Knoxville Police Department. There were cameras set up in the shop that were being monitored by the police, and Gary and Stover’s actions in the shop were filmed and recorded. Upon leaving the store, Gary and Stover were confronted by the police and exchanged gunfire with the officers. Carson, Gary, and Stover were soon apprehended. Gary and Stover pleaded guilty to numerous criminal charges. Carson was charged and convicted of aggravated robbery, aggravated assault, and felony reckless endangerment and sentenced to 51 years in prison. Carson appealed, and the court of appeals affirmed his conviction. The case came before the Tennessee Supreme Court, with Carson alleging that he should not have been convicted for the assault and endangerment charges because he lacked the culpable mental state for those offenses committed by Gary and Stover beyond the robbery.