Proof that defendant only aided or abetted commission of crime will support conviction on indictment for substantive offense

Aiding-and-Abetting United States v. Ellis, No. 06-6340, ___ F.3d ___ (10th Cir. May 12, 2008)(W.D. Oklahoma). Appeal of conviction for bank robbery. HELD: Aiding and abetting is not an independent crime. However, aiding-and-abetting statute applies implicitly to all federal offenses and even though defendant is charged with commission of substantive offense, proof that he or she only aided or abetted commission of crime will support indictment. Read the opinion here.