State v. Nicholas Haffner

Syllabus

The defendant appealed from a conviction after a jury trial on one count of assault with a dangerous weapon and one count of driving under the influence. He asserted that the jury instruction on aiding and abetting was erroneous because the evidence supported only criminal liability as a principal. He also argued that the trial justice committed reversible error during the hearing conducted pursuant to Missouri v. Frye, 566 U.S. 134 (2012). The Supreme Court held that the trial justice properly instructed on aiding and abetting because it is not a separate element of a crime. The Court also held that the defendant waived any objection to the substance of the instruction. Finally, the Court held that the defendant had waived any challenge to the Frye hearing. Accordingly, the Supreme Court affirmed the judgment of conviction.