People of Michigan v. Chester Curtis Meriwether, 326618

Nonfatal shooting in a Detroit Coney Island parking lot; victim was shot during an attempted robbery.
Defendant (Meriwether) drove two men (“Quez” and “O”) who said they wanted to rob someone; he dropped O off at the Coney Island lot and waited nearby as a getaway driver.
Defendant watched O approach and saw O shoot the victim; defendant then drove O and Quez away and dropped them off where he had picked them up.
Defendant was charged with multiple offenses, including armed robbery; at a bench trial the court found O committed an armed robbery but found defendant did not know O was armed or intended to shoot the victim before the offense.
The trial court nonetheless convicted defendant of armed robbery under an aiding-and-abetting theory, reasoning defendant knowingly assisted the robbery by driving the principals and acting as the getaway driver.
Defendant appealed, arguing the armed-robbery conviction was inconsistent with the court’s findings that he lacked knowledge that O was armed or intended an armed robbery.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the conviction for armed robbery (aiding and abetting) is inconsistent with the court’s findings that defendant did not know O was armed or intended an armed robbery	The verdict is consistent: defendant knowingly aided a robbery by driving the principals and acting as getaway driver; armed robbery is a natural and probable consequence of robbery so intent to assist a robbery suffices	The conviction is inconsistent because the court found defendant lacked knowledge that O had a gun or intended an armed robbery, which is an essential element of armed robbery	Affirmed: conviction consistent. Aiding-and-abetting liability may be based on intent to assist a robbery and on the natural-and-probable-consequences theory, so defendant could be guilty of armed robbery even without specific knowledge that a weapon would be used

People v. Russell, 297 Mich. App. 707 (case discussing review standard for inconsistency)
People v. Chambers, 277 Mich. App. 1 (elements of armed robbery)
People v. Robinson, 475 Mich. 1 (aiding and abetting standards; intent and natural-and-probable-consequences theory)
People v. Norris, 236 Mich. App. 411 (aiding-and-abetting precedent)
People v. Smielewski, 235 Mich. App. 196 (aiding-and-abetting precedent)
People v. Young, 114 Mich. App. 61 (holding weapon use may be within scope of a robbery and conviction may stand without defendant’s knowledge that principal was armed)
In Re Guilty Plea Cases, 395 Mich. 96 (discussing scope of common enterprise and consequences)
People v. Ellis, 468 Mich. 25 (a judge must render a consistent verdict)