South Carolina v. YoungAnnotate this Case
In the course of a gun battle between mutual combatants, a bullet fired at Petitioner Aaron Young Jr. (Young Jr.) missed its intended mark and killed an unintended victim. Young Jr. and his father Aaron Young Sr. (Young Sr.) willingly engaged a rival, Tyrone Robinson, in a residential neighborhood. The battle ended when Robinson shot and killed an unintended victim, an eight-year-old child who was playing in the area. The State charged all three combatants with the murder of the victim. Robinson's murder charge stemmed from a straightforward application of the doctrine of transferred intent. The Youngs' murder charges stemmed from an application of the doctrine of mutual combat. The South Carolina Supreme Court held mutual combat could properly serve as the basis for a murder charge for the death of a non-combatant under the "hand of one is the hand of all" theory of accomplice liability. The Court therefore found the law sanctioned holding Young Jr. responsible for the actions of Robinson in causing the victim's death, and affirmed Young Jr.'s murder conviction and sentence.