## Facts

- On March 22, 2014, Antonio Lamar Stimpson and two accomplices drove around Greensboro, North Carolina, in a Jeep, wearing dark clothing and face coverings, and carried out a short, early-morning series of armed robberies and attempted robberies.
- The group repeatedly used coordinated tactics (blocking victims with their vehicle, approaching with firearms, and acting in concert) across multiple incidents over roughly two to three hours.
- In one incident near a hair salon, two masked men confronted a victim as she tried to leave, demanded money at gunpoint, a shot was fired near her head, and the men drove away in her vehicle.
- In another incident at a residence, multiple shots were fired at victims near and inside a vehicle; the perpetrators took property and fled.
- Police later recovered from the Jeep items consistent with a planned series of robberies, including gloves, face coverings, and stolen property.
- There was no direct testimony of an express agreement among the perpetrators; the State relied on circumstantial evidence from their coordinated conduct.
- A jury convicted Stimpson of multiple offenses, including five counts of conspiracy to commit robbery with a firearm.

## Issues

1. Whether the evidence was sufficient to permit the jury to find multiple, distinct conspiracies to commit robbery with a firearm, rather than a single overarching conspiracy, so that four challenged conspiracy convictions could stand.

## Decision

- The North Carolina Court of Appeals affirmed, holding the trial court properly denied Stimpson’s motion to dismiss four conspiracy counts and properly submitted multiple conspiracy charges to the jury.
- The court concluded the evidence allowed a reasonable inference of separate agreements associated with different robberies or attempted robberies involving different victims and locations.
- The North Carolina Supreme Court later affirmed per curiam.

## Legal Principles

- Criminal conspiracy is an agreement between two or more persons to commit an unlawful act (or a lawful act by unlawful means); the agreement is the offense, and no overt act is required.
- Conspiracy may be proven by circumstantial evidence and inferred from coordinated actions and surrounding circumstances.
- Whether conduct reflects one conspiracy or multiple conspiracies turns on whether there was one agreement or several; relevant considerations include time intervals, locations, objectives, number of victims, and whether new agreements can reasonably be inferred as events unfold.
- When the evidence permits competing inferences on one-versus-many conspiracies, the issue is generally for the jury under the substantial-evidence standard viewed in the light most favorable to the State.

## Conclusion

The court upheld multiple conspiracy convictions arising from a tightly timed robbery spree, reasoning that separate implied agreements could be inferred as the perpetrators moved to different locations and targeted new victims, even without direct proof of explicit discussions.


State v. Stimpson, 256 N.C. App. 364, 807 S.E.2d 603 (2017)