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Maine law is instructive. The 'foreseeable consequence' or 'natural and probable consequence' rule in complicity law has been stated as follows: 'an accessory is liable for any criminal act which in the ordinary course of things was the natural or probable consequence of the crime that he advised or commanded, although such consequence may not have been intended by him.' 22 C.J.S. Criminal Law § 92 (1961) (footnote omitted). See also Robinson, Imputed Criminal Liability, 93 Yale L.J. 609, 617 & n. 24 (1984); Kadish, Complicity, Cause and Blame: A Study in the Interpretation of Doctrine, 73 Calif. L. Rev. 323, 353 & n. 69 (1985); Dressler, Reassessing the Theoretical Underpinnings of Accomplice Liability: New Solutions to an Old Problem, 37 Hastings L.J. 91, 97 & n. 30 (1985); Comment, Wisconsin's Party to a Crime Statute: The Mens Rea Element Under the Aiding and Abetting Subsection, and the Aiding and Abetting-Choate Conspiracy Distinction, 1984 Wis. L. Rev. 769, 787-789 (1984); but cf. LaFave & Scott, Criminal Law § 65 at 515-517 (1972). 


The rule has also been adopted in several other jurisdictions. See Wis. Stat. Ann. § 939.05 (2)(c) (West 1982); Minn. Stat. Ann. § ...

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