State of New Jersey, Plaintiff-Respondent v. Oliver White, Defendant-Appellant

Summary

The Supreme Court of New Jersey held that an accomplice to an armed robbery is subject to the mandatory minimum sentencing provisions of the Graves Act both when the accomplice is convicted of an armed robbery and when, although convicted of an unarmed robbery, the accomplice knew or had reason to know that a co‑offender would use or possess a firearm. The Court based its holding on a purposive construction of the Graves Act and the definition of accomplice liability under the New Jersey Criminal Code. The judgment of conviction was affirmed. Justice Handler dissented, arguing that the Act should apply only to persons who actually possess or use a firearm.