State v. Thomas, 387 S.W.3d 432

Thomas appeals a jury verdict finding him guilty of manufacturing a controlled substance by packaging and possessing marijuana with intent to deliver.
A no-knock warrant was executed at 718 East 9th Street, Sedalia, Missouri; Wright owned the residence and Brooks and Thomas were present.
Police found marijuana, packaging supplies, a scale, a coffee grinder, and $1004 on Wright; Thomas had 28 grams in 15 baggies on his person.
Wright admitted he dealt in marijuana and that Brooks and Thomas helped him package it for sale; Thomas admitted using marijuana and packaging, but claimed the pocket baggies were for personal use.
The State alleged Thomas aided or encouraged Wright/ Brooks in manufacturing by packaging and possessing with intent to deliver; the jury was instructed on accomplice liability.
Thomas challenged sufficiency of evidence to prove accomplice liability; the trial court denied motions for acquittal and new trial, and the verdicts were affirmed on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence supports accomplice liability for manufacturing by packaging	Thomas aided Wright/ Brooks by packaging.	Thomas alone packaged; no evidence of Wright/ Brooks packaging.	Sufficiency supported accomplice liability; conviction affirmed.
Whether evidence supports accomplice liability for possession with intent to deliver	Packaging and possession indicate aiding or encouraging sale.	Thomas packaged for himself; no aiding by Wright/ Brooks.	Sufficiency supported accomplice liability; conviction affirmed.

State v. Wilson, 359 S.W.3d 60 (Mo.App. W.D.2011) (sufficiency review; standard for judgment of acquittal)
State v. Isa, 850 S.W.2d 876 (Mo. banc 1993) (abolished principal/accessory distinction; accomplice liability applicable)
State v. Davis, 963 S.W.2d 317 (Mo.App. W.D.1997) (accomplice liability viability alongside principal theory)
State v. Young, 369 S.W.3d 52 (Mo.App. E.D.2012) (encouragement suffices for accomplice liability)