People v. Phillips

Defendant was convicted, after bench trial, of first-degree murder and unlawful possession of a weapon by a felon. Although Defendant intended to give woman a black eye, after she gave his girlfriend a black eye, the person accompanying Defendant for "crowd control" fired a gun toward direction of crowd, killing one person. State proved Defendant guilty of first-degree murder beyond a reasonable doubt. Defendant cannot escape liability merely because his criminal intentions did not rise to level of murder. By attaching himself to a group bent on illegal acts, Defendant became accountable for all crimes of his companions, including shooting by his companion. Rational trier of fact could have concluded that Defendant did not withdraw from common criminal design so as to negate his legal accountability. Shared intent is not an element of common-design rule. (KNECHT and HARRIS, concurring.)