Leon Robinson and Shanika Robinson v. United States
100 A.3d 95
| D.C. | 2014Background
- Shanika and Leon Robinson were convicted of multiple offenses connected to an armed robbery and murder of Shahabuddin Rana in 2009.
- The central issue is the mens rea required for an aider and abettor to face the §22-4502 (armed) enhancement when a violent crime is committed while armed.
- Court held that an unarmed aider and abettor must know that the principal (or another accomplice) is armed to be eligible for the enhancement.
- The trial court instructed the jury that a defendant need only have reason to know the principal is armed, which was erroneous.
- Jury exchanged questions about when knowledge is required and the timing of knowing that weapons were present; final instruction focused on knowledge at the time of entry.
- The court reversed Shanika Robinson’s four armed-count convictions and remanded with option to enter judgments on unarmed lesser offenses, while affirming Leon Robinson’s convictions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Aider and abettor knowledge standard | Robinson argued mere reason to know sufficed under Fox. | Robinson argued actual knowledge required under Wilson-Bey. | Actual knowledge required; instruction erroneous. |
| Prejudice and relief for instructional error | Error affected all armed offenses. | Error limited to burglary-armed count. | Error prejudicial; vacate four armed counts and remand with option for unarmed convictions. |
| Severance and other claims | Leon argued denial of severance prejudiced him. | Leon asserted trial was prejudicial but severance improper. | Severance denied; no reversible error shown; other claims rejected. |
Key Cases Cited
- Fox v. United States, 11 A.3d 1282 (D.C. 2011) (post-Wilson-Bey interpretation allowing knowledge that principal will be armed)
- Wilson-Bey v. United States, 903 A.2d 818 (D.C. 2006) (en banc; mens rea for aiding and abetting armed offenses)
- Rosemond v. United States, 134 S. Ct. 1240 (2014) (requires knowing in advance accomplice would be armed for aiding and abetting)
- Kitt v. United States, 904 A.2d 348 (D.C. 2006) (specific mens rea required for aider and abettor of robbery)