New York Court of Appeals
The People of the State of New York v. . Courtland H. Bliven
January 15, 1889112 N.Y. 79
Summary
The Court of Appeals affirmed the conviction of Cortlandt H. Bliven for abortion, holding that under Penal Code §29 a person may be convicted as a principal even if he was absent at the commission of the crime but aided, advised, or procured it. The Court also held that the indictment was sufficient because it plainly charged the act of procurement, allowing proof of the defendant's guilt through his counsel and assistance.