Baker v. Alaska

Donald Baker (defendant) and his friends, John Stanfill and Jason Frazier, devised a plan to rob a pizza deliveryman. After calling and directing a restaurant to deliver pizzas to a fake address, the three robbers hid and waited. When the deliveryman arrived, he could not find the person who had placed the order, and turned around to leave. One of the robbers emerged and repeatedly struck the deliveryman. The deliveryman dropped the pizzas, which were picked up by two of the robbers, and all three robbers fled. The deliveryman could not identify the robber who had hit him. All three robbers were arrested. At Baker’s trial, the prosecution indicated that Baker was a principal to the robbery and that the theory of the case was that Baker was the robber who had hit the deliveryman. The prosecution stated that the jury could convict Baker even if the jury did not believe that Baker had hit the deliveryman, as long as the jury did believe that Baker was one of the three robbers. At the end of the trial, the judge instructed the jury on accomplice liability. Baker was convicted. Baker appealed to the Court of Appeals of Alaska, arguing that the trial court erred in instructing the jury on accomplice liability because this allowed Baker to be convicted as an accessory to the crime even though the state’s theory of the case was that he was a principal. Additionally, Baker argued that the indictment charging him with robbery did not put him on sufficient notice that he could be convicted as either a principal or an accessory to the robbery.