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State v. Gladstone
Supreme Court of Washington (1980)
Defendant: Bruce Gladstone; the defendant was known to be a drug dealer on a college campus and the police sent to him a student whose task was to buy marijuana from the defendant. The defendant told the student that he did not have any marijuana at the moment and he told the student that if he needs marijuana, he should go to Robert Kent. The defendant drew a map indicating the directions of the house of Kent for the student. The student went to Kent and Kent sold him Marijuana. Now the defendant is convicted with aiding and abetting Kent in the unlawful sale of marijuana.
Issue: Did the defendant aid and abet Kent in the sale of marijuana by merely leading a potential buyer to Kent's house?
Holding: No
Key Facts: Even though there was evidence that the defendant gave the student a map of Kent's house, there was no evidence indicating that the defendant and Kent made any verbal or other types of communications with each other.
Legal Reasoning: The court held that in order for the defendant to aid or abet a criminal act, he must "in some sort associate himself with the venture, that he participate in it as something that he wishes to bring about, that he seek by his action to make it succeed." The court ruled that it was not ready to extend this rule to the defendant's actions where he only told a student that he might be able to find marijuana from Kent and he did not make any deals or communication with Kent. The conviction was reversed.