Laye v. State

Although mere presence at the scene of crime and merely driving a getaway car are insufficient standing alone, if a defendant had knowledge of the intended crime and shared the criminal intent of main actor, he is an aider and abettor.

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Randall Laye appeals his conviction for armed robbery arising out of an incident in Carrollton that led the State to charge nine individuals with murder, armed robbery, aggravated assault, cruelty to children, and other crimes. Laye was tried with co-defendant Chade Ackey, and, although both were charged with 17 crimes, Laye was convicted only of armed robbery and sentenced to life, and Ackey was acquitted on all counts. The State’s primary evidence inculpating Laye came from Christopher Coleman, the only person who pled guilty and agreed to testify against Laye and Ackey. On appeal, Laye enumerates several errors concerning evidence of corroboration: that the corroborative evidence was insufficient; that the court erred by failing to give a limiting instruction regarding a custodial statement by co-defendant Ackey that implicated Laye; that, for the same reasons, the court erred by denying Laye’s motion to sever his trial from Ackey; and that trial counsel was ineffective by failing to request a limiting instruction regarding Ackey’s statement. One other alleged error will be addressed, as well.

Because the main issue concerns corroboration of Coleman’s testimony, we will begin there. Coleman pled guilty to murder, armed robbery, multiple counts of aggravated assault, multiple counts of cruelty to children, and possession of a firearm by a convicted felon; he is serving life plus 10 years. He testified to the following: He was 19 years old in July 2006, and, although he had been in Carrollton for only about five weeks, he had made friends with several young men there, including LaBryan Lytle, Varion “Snoopy” Shell, Arlandra Deonte “Red” Holland, and Aerius “P” Potts. On the night of July 19, Coleman arranged to borrow a white Neon car from a friend; he then rounded up the above group of young men. They had a plan to go to LaGrange and possibly rob someone there, but when the events unfolded in Carrollton, they decided to use the story that they went to LaGrange as an alibi.

Laye v. State

Although mere presence at the scene of crime and merely driving a getaway car are insufficient standing alone, if a defendant had knowledge of the intended crime and shared the criminal intent of main actor, he is an aider and abettor.

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