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Standefer v. United States | 447 U.S. 10 (1980)
Under the federal aiding-and-abetting statute, any person who, quote, “commits an offense against the United States, or aids, abets, counsels, commands, induces, or procures its commission, is punishable as a principal,” unquote. But what if the principal has been acquitted of the underlying offense? May a defendant still be held liable for aiding and abetting? In Standefer versus United States, the United States Supreme Court addressed this issue.
In February of nineteen seventy-seven, Cyril Niederberger, an Internal Revenue Service agent, was charged with ten counts of accepting improper payments, in violation of federal law. The government alleged that Niederberger, who performed audits of Gulf Oil Corporation’s federal income tax returns, received money from Gulf for five vacations. Niederberger was tried and convicted of six of the counts but acquitted of four of the counts for three of the five vacations.
In addition, in June of that year, Fred W. Standefer, the head of Gulf Oil’s tax department, was charged with four counts of making gifts to a public official and five counts of aiding and abetting Niederberger. Prior to trial, Standefer moved to dismiss the aiding-and-abetting charges in connection with the counts that Niederberger had been acquitted of. Further, Standefer argued that the doctrine of non-mutual collateral estoppel barred the government from relitigating Niederberger’s guilt to determine whether Standefer aided and abetted his crimes.
The district court denied the motion, and following trial, the jury returned guilty verdicts on all nine counts. Standefer appealed to the Third Circuit, arguing that he couldn’t be convicted of aiding and abetting when the principal had been acquitted of the charged offense. The Third Circuit, by a divided vote, affirmed. The United States Supreme Court then granted cert.
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