## Facts

- Bennie Eugene Bridges attended a birthday party in Roebling, New Jersey, and argued with another guest, Andy Strickland.
- After the confrontation, Bridges left the party, threatened to return with his “boys,” and drove to Trenton.
- Bridges met Keith D. Bing and Eddie E. Rolle and asked them to return to the party because he expected a confrontation.
- On the way back, Bing and Rolle went into a house briefly; when they returned, they indicated they had brought “some stuff,” which Bridges understood to mean weapons (guns or knives).
- Back in Roebling, Bridges fought Strickland in the street while a crowd gathered.
- During the melee, Bing and Rolle produced guns and fired into the crowd, killing Shawn Lockley and wounding Paul Suszynski.
- Bridges and the others fled, hid the guns, and attempted to avoid apprehension; they were later arrested.
- A jury convicted Bridges of conspiracy and multiple substantive offenses (including murder and aggravated assault) under a vicarious co-conspirator liability instruction.
- The Appellate Division affirmed the conspiracy conviction but reversed the substantive convictions, reasoning that co-conspirator liability required specific intent for the substantive crimes; a dissent would have applied a foreseeability standard.

## Issues

1. Under N.J.S.A. 2C:2-6(b)(4), may a conspirator be held liable for substantive crimes committed by co-conspirators that were not within the original agreement if those crimes were reasonably foreseeable as necessary or natural consequences of the conspiracy?
2. Does co-conspirator vicarious liability require the same specific intent required for accomplice liability for the substantive offense, or may it rest on an objective reasonable-foreseeability standard?

## Decision

- The Supreme Court of New Jersey reversed the Appellate Division and reinstated Bridges’s substantive convictions.
- The court held that, under N.J.S.A. 2C:2-6(b)(4), a co-conspirator may be liable for substantive offenses outside the precise scope of the agreement when those offenses are committed in connection with the conspiracy and are reasonably foreseeable as necessary or natural consequences.
- The court rejected importing accomplice-liability “purpose” requirements into the separate statutory basis for conspirator vicarious liability.
- Applying the objective foreseeability test, the court concluded the shooting and resulting death and injury were reasonably foreseeable consequences of returning to the party with armed reinforcements expecting a confrontation.

## Legal Principles

- N.J.S.A. 2C:2-6(b)(4) imposes vicarious conspirator liability for substantive offenses committed by another when the offenses are committed in the course of, in furtherance of, or as an incident of or in connection with the conspiracy.
- A conspirator is liable for co-conspirators’ substantive crimes if those crimes were reasonably foreseeable as the necessary or natural consequences of the conspiracy.
- The foreseeability inquiry is objective; liability does not depend on the defendant’s purpose to bring about the particular substantive offense.
- Accomplice liability under N.J.S.A. 2C:2-6(c) requires purpose to promote or facilitate the offense; conspirator vicarious liability under N.J.S.A. 2C:2-6(b)(4) is broader and is grounded in the conspiratorial agreement plus foreseeability.

## Conclusion

The court upheld Pinkerton-style conspirator liability under New Jersey’s criminal code, ruling that a defendant who joins a conspiracy can be convicted of co-conspirators’ substantive crimes when those crimes are committed in connection with the conspiracy and were objectively foreseeable consequences of the conspiratorial plan.


State v. Bridges, 133 N.J. 447, 628 A.2d 270 (N.J. 1993)