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State ex rel. Woods v. Cohen

Supreme Court of Arizona
844 P.2d 1147 (Ariz. 1992)


Edwin Cohen (defendant) was indicted for conspiracy to defraud the Arizona health-care system. Count 1 of the indictment charged Cohen with conspiracy, while counts 18 through 29 charged Cohen with various substantive offenses committed by co-conspirators. Cohen moved to dismiss counts 18 through 29, arguing that there was insufficient evidence to support those charges. The trial court granted Cohen’s motion and remanded those counts to the grand jury. In a special action before the court of appeals, the state argued that the trial court had incorrectly rejected the Pinkerton doctrine of vicarious liability, which would have supported Cohen’s liability for substantive crimes committed by co-conspirators, even though Cohen had not participated in the crimes. The state contended that co-conspirator liability was included within accomplice liability. State law defined an accomplice as anyone who, while intending to encourage or facilitate an offense, aided or tried to aid another person in planning or committing the crime. The grand jury had been instructed on Pinkerton liability, and the state conceded that there had not been any evidence showing that Cohen had participated directly in any of the offenses in counts 18 through 29. The court of appeals reversed the trial court’s order and remanded the case for further proceedings on the indictment. Cohen petitioned the Supreme Court of Arizona for review.

Rule of Law


Holding and Reasoning (Martone, J.)

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