State v. Gilbert Delestre

Summary

The Rhode Island Supreme Court affirmed the conviction, holding that the trial judge's aiding‑and‑abetting instruction did not violate due‑process because it did not create a conclusive presumption or shift the burden of proof, and that a jury need not be unanimous on the theory (principal, aider‑abetter, or co‑conspirator) for a second‑degree murder conviction. The Court relied on established de novo review of jury instructions and on precedent that unanimity is required only for the ultimate elements of the crime.