## Facts

- Jubal Carson and two associates planned to rob a Knoxville business.
- Carson provided “inside information” about the store layout and the location of cash in a back room.
- Carson furnished firearms, giving a handgun to each associate.
- The three drove to the location together; Carson remained in the car while the others entered under a pretense.
- Inside, the associates held two employees at gunpoint, forced them to a rear room, took money, bound them with telephone cord, and fired multiple shots through the door, narrowly missing them.
- As the associates exited, police confronted them; Carson and the vehicle were gone, and the associates fled while exchanging gunfire with officers.
- The store was an undercover police operation; events were monitored and recorded.
- Carson later admitted driving the associates to the area but denied knowledge of a planned robbery; the jury rejected this account.
- A jury convicted Carson of aggravated robbery, two counts of aggravated assault, and felony reckless endangerment; the intermediate appellate court affirmed based on criminal responsibility for co-defendants’ acts.

## Issues

1. Whether Tenn. Code Ann. § 39-11-402(2) makes a defendant who intentionally aids an aggravated robbery criminally responsible for additional offenses committed by co-participants during the robbery.
2. Whether Tennessee’s criminal responsibility statutes incorporate the common-law “natural and probable consequences” doctrine, extending liability to reasonably foreseeable collateral crimes.

## Decision

- The Tennessee Supreme Court affirmed the convictions.
- The court held Carson was criminally responsible under Tenn. Code Ann. § 39-11-402(2) for aggravated robbery and for the additional offenses committed by his associates.
- The court concluded the common-law natural-and-probable-consequences rule applies under the statutory scheme.
- The court found sufficient evidence that Carson intentionally promoted or assisted the robbery by planning, supplying weapons, providing inside information, and serving as the driver/lookout.
- The aggravated assaults and reckless endangerment were deemed reasonably foreseeable consequences of an armed robbery involving confinement of victims and an attempted escape.

## Legal Principles

- Under Tenn. Code Ann. § 39-11-402(2), a person is criminally responsible for an offense committed by another when, with intent to promote or assist the commission of the offense (or to benefit from it), the person solicits, directs, aids, or attempts to aid the other to commit the offense.
- Tennessee’s criminal responsibility statutes incorporate the common-law rule that an accomplice to a target offense is also liable for other crimes committed by the principal that are the natural and probable consequences of the target offense.
- The accomplice need not specifically intend each collateral offense if the accomplice intentionally assisted the target crime and the collateral crimes were reasonably foreseeable in carrying it out.

## Conclusion

Because Carson intentionally aided an armed robbery by planning it and supplying guns, and because gunfire and endangerment of victims were reasonably foreseeable consequences of that robbery, Tennessee law permitted his conviction for the additional assaults and reckless endangerment committed by his confederates.


State v. Carson, 950 S.W.2d 951 (Tenn. 1997)