State v. Eyre
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The Supreme Court vacated Defendant's conviction of accomplice to aggravated robbery, a first degree felony, under a theory of accomplice liability, holding that the trial court gave an erroneous mens rea instruction to which trial counsel should have objected and this failure to object prejudiced Defendant.
At issue was a jury instruction detailing the mens rea required to convict under an accomplice-liability theory. On appeal, Defendant argued that the jury instruction was erroneous and that trial counsel was deficient in failing to object to it. The court of appeals affirmed the conviction, concluding that the instructions adequately instructed the jury on accomplice liability for aggravated robbery. The Supreme Court reversed, holding (1) the jury instruction at issue was erroneous and that trial counsel performed deficiently in failing to object to it; and (2) trial counsel's deficient performance prejudiced Defendant.
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