Case brief summary
If people team up to plan a crime and one of them commits other crimes to carry out that plan, everyone in the group can be guilty too, if those crimes were a predictable part of the plan.
Facts
Brothers Walter and Daniel Pinkerton were charged with tax fraud from illegal liquor sales. Walter committed the actual crimes while Daniel, sometimes in prison, didn't, but they had an ongoing agreement to commit these crimes together.
Procedural history
A jury convicted both brothers of conspiracy and related crimes. An appeals court upheld this. The Supreme Court took the case because another appeals court had ruled differently on a similar issue.
Issue
Can someone be convicted of a specific crime that he did not personally commit, simply because he had agreed with another person to a continuing criminal scheme and the other person committed that crime to carry out their shared plan?
Holding
Yes. The Supreme Court upheld Daniel's convictions for the specific crimes committed by Walter, because those crimes were done to carry out the conspiracy the brothers had agreed to, and Daniel never took any action to withdraw from that agreement.
Reasoning
The Court explained that agreeing to commit a crime (conspiracy) and actually committing that crime are two separate offenses, so being charged with both is not unfair double punishment. Because the brothers were engaged in an ongoing partnership in crime, each one's actions taken to carry out their shared plan count as the actions of both, unless a member clearly withdraws from the agreement, which Daniel never did.
Opinions
Majority (Douglas): Agreeing to a conspiracy makes each member responsible for crimes committed by any member to carry out the plan, as long as those crimes were foreseeable results of it.
Dissent (Rutledge): Daniel should not be guilty of crimes only Walter committed just because they once agreed to a general criminal scheme, since Daniel did not know of or help with those specific acts.