Illinois Appellate Court
Criminal Court
Accountability Theory
(Court opinion corrected 4/22/10.) Defendant, alleged to be robbery getaway driver, was convicted of first-degree murder on theory of accountability, after store manager was found shot to death by gun that was never recovered. The only physical evidence of murder was the bullet which killed the victim, and which did not match the recovered gun. Evidence shows only that Defendant shared common design with those who committed attempted armed robbery, for which Defendant could have been held accountable, but not the murder. Evidence at trial fell short of what is required in accountability case for felony murder, creating reasonable doubt as to Defendant's guilt.