Enmund v. Florida

The state of Florida charged Earl Enmund, the petitioner, with first-degree murder and robbery perpetrated against two elderly people. The Florida Supreme Court upheld this decision, although it recognized that the court could only infer that Enmund drove the car that helped the killers, Sampson and Jeanette Armstrong, escape. Under Florida law, the state could prosecute Enmund as a constructive accomplice because he drove the getaway car, considering him equally responsible for the homicides.

Based on witness testimony, the court deduced that Enmund had driven the Armstrongs to and from the scene of the crime, although no direct evidence existed. According to the court's theory, Enmund waited in the car while the Armstrongs pretended to need water to stop his car from overheating. Sampson Armstrong then pulled a gun on one of the residents, Thomas Kersey. Kersey called his wife for help, who came out with a gun and shot Jeanette Armstrong, wounding her. After that, Sampson Armstrong killed and robbed the Kerseys. Then the Armstrongs fled in the car driven by Enmund.