## Facts

- Michael Gains and Lonnie Williams, along with a juvenile accomplice, robbed a bank while armed with handguns.
- The three men took approximately $1,000 from one teller and approximately $26,000 from another teller.
- After the robbery, the three men calmly left the bank with their guns and the money concealed.
- They walked slowly across the parking lot to a car parked on the far side of the lot, facing away from the bank.
- Joseph Williams was waiting in the car in the driver’s seat and did not enter the bank.
- When the three robbers got into the car, Joseph drove away slowly and normally, obeying traffic signals and the speed limit.
- Police were alerted, and a police officer attempted to stop the vehicle.
- The officer observed the passengers suddenly begin talking to Joseph, after which Joseph changed his driving and tried to elude the police.
- During the brief chase, Lonnie fired his gun at the police car.
- The getaway car crashed, and Gains, Lonnie, and Joseph were apprehended.
- All three defendants were charged and convicted of two counts of armed robbery; Joseph’s convictions were based on principal (accomplice) liability.

## Issues

1. Whether the State’s wholly circumstantial evidence was sufficient to prove beyond a reasonable doubt that Joseph Williams knowingly participated in the armed robberies as a principal, rather than learning of the robberies only after the gunmen returned to the car.

## Decision

- The court affirmed the armed-robbery convictions of Gains and Lonnie Williams.
- The court reversed Joseph Williams’s armed-robbery convictions for legally insufficient evidence of knowing participation as a principal.

## Legal Principles

- A defendant may be convicted as a principal if the State proves the defendant intended the crime be committed and assisted or encouraged its commission.
- When the State relies entirely on circumstantial evidence, that evidence must be consistent with guilt and inconsistent with any reasonable hypothesis of innocence.
- Conduct that is equally consistent with innocent behavior and guilty knowledge (such as being present in a car and later attempting to evade police) does not, by itself, prove prior knowledge of, and intent to assist, the underlying robbery.
- Assistance provided only after the offense is completed may support accessory-after-the-fact liability, but it does not establish principal liability for the completed robbery without proof of advance knowledge and shared intent.

## Conclusion

In *Gains v. State*, the First District held that Joseph Williams’s role as the driver, combined with his later flight after the passengers spoke to him, did not exclude a reasonable possibility that he learned about the bank robbery only after the robbers returned to the car; because the State’s proof of his intent and knowledge was wholly circumstantial and inadequate to show he was a principal to the robberies, his armed-robbery convictions were reversed while the convictions of the armed robbers who entered the bank were affirmed.


Gains v. State, 417 So.2d 719 (1982)