Commonwealth v. Knox, J., Aplt., 105 A.3d 1194

Appellant was charged with illegal possession of a firearm by another under accomplice liability theory in a larger criminal undertaking.
The weapon was actually possessed by Appellant's brother; Appellant was unarmed during the episode.
The Superior Court adopted an expansive view that accomplice liability extends to possessory weapons offenses abstractly, based on a theory that co-perpetrators are criminally liable for each other’s actions.
The Crimes Code § 306(c) requires offense-specific analysis focusing on intent to promote or facilitate the specific offense.
The trial court's jury charge included theories of conspiracy, as well as constructive and joint possession, to sustain the possessory offense.
This Court affirmed the Superior Court’s result but disapproved the reasoning that supported the possessory offense on the broader accomplice theory.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether accomplice liability can sustain a possession offense for a firearm by another.	Knox argues liability extends to abstract accomplice conduct.	Appellant contends liability requires intent to promote a specific offense, not general accomplice theory.	Liability must be offense-specific; abstract accomplice theory alone is insufficient.
Whether the conspiracy theory independently supports a possession conviction when not charged with conspiracy to possess.	The jury could rely on conspiracy liability to sustain the conviction.	Conspiracy liability is inappropriate for a possession conviction if not charged as conspiracy.	Conspiracy cannot sustain the charge by itself; but other independent bases (accomplice or possession theories) can.
Whether the conviction can stand given multiple independent bases presented to the jury.	Any sufficient predicate supports the conviction.	No single challenged basis is necessary if others fail.	Conviction affirmed because independent bases supported the verdict.

Commonwealth v. Roebuck, 612 Pa. 642 (Pa. 2011) (clarifies the relationship between C.C. and MPC concepts in complicity)
Commonwealth v. Flanagan, 578 Pa. 587 (Pa. 2004) (limits on common-design and natural-and-probable-consequences doctrines)
Commonwealth v. Smith, 490 Pa. 329 (Pa. 1980) (addressing accountability for firearm possession under felonious conduct)
Commonwealth v. Knox, 50 A.3d 749 (Pa. Super. Ct. 2012) (discusses accomplice liability in possessory offense context)
State v. Williams, 315 N.J. Super. 384 (N.J. 1998) (common problem of accomplice liability where weapon is possessed by co-perpetrator)