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Washington law is instructive. Under Washington law, '[u]nless otherwise provided by this title or by the law defining the crime, a person is not an accomplice in a crime committed by another person if: (a) He is a victim of that crime.' RCW 9A.08.020(5). The word 'victim' is not specifically defined anywhere in the Washington Criminal Code, Title 9A RCW, or in Washington motor vehicle statutes, Title 46 RCW. Unrelated laws, such as the Sentencing Reform Act of 1981 (chapter 9.94A RCW) and the crime victims' compensation act (chapter 7.68 RCW) are in accord with the common understanding that a 'victim' is a person who suffers injury as a direct result of a crime. See RCW 9.94A.030(46); RCW 7.68.020(3);3 WEBSTER'S II NEW RIVERSIDE UNIVERSITY DICTIONARY 1286 (1984) ('One harmed or killed by another.'); cf. BLACK'S LAW DICTIONARY 1598 (8th ed.2004) ('[a] person harmed by a crime, tort, or other wrong'). 

The statute appears to be a codification of a much older common law rule dating at least back to an 1893 English statutory rape case, where the court reasoned that a law intended to protect young girls could not also hold them responsible as accomplices. The ...

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