United States Court of Appeals for the District of Columbia
52 A.3d 858 (2012)
Snowden (defendant) and four others robbed Lorenzo Ross and Martin Scales at gunpoint outside Ross’s apartment building. A second gunman arrived on the scene and kept a gun aimed at the victims while Scales surrendered $20 to Snowden. After a tussle during which Scales tried to disarm Snowden, Snowden and his cohorts fled. The second gunman remained behind, with the gun pointed at Scales. About 15 seconds after Snowden and the others fled, the gunman shot Scales in the abdomen. Snowden was convicted of numerous crimes, including aggravated assault while armed for Scales’s shooting. Snowden’s liability was based on a conspiracy theory, with armed robbery as the underlying crime. On appeal, Snowden argued that the conviction for aggravated assault should be vacated, because the evidence was insufficient to show that Scales was shot in furtherance of the conspiracy and that the shooting was a reasonably foreseeable consequence of the conspiracy.
Rule of Law
Holding and Reasoning (Ruiz, J.)
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