Uploaded February 2025 | Updated September 2026, 2 weeks ago
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Halberstam v. Welch - United States Court of Appeals for the District of Columbia Circuit
705 F.2d 472 (1983)
If you help another person commit a tort, can you be held liable to a third party who's injured as a result? We explore that question in Halberstam versus Welch.
Bernard Welch made a living by burglarizing people's homes and selling the stolen goods. Welch had no outside employment and few assets when he met and moved in with Linda Hamilton.
Nevertheless, the couple was able to purchase a million dollar home within a few years. Welch shot and killed Michael Halberstam while burgling Halberstam's home. Elliot Jones Halberstam, Halberstam's wife, sued Welch and Hamilton for Halberstam's wrongful death.
Evidence presented before the trial court established that Welch routinely left the couple's home for several hours during the evenings.
Hamilton claimed that she didn't know what Welch did on his outings. However, Hamilton kept the books for Welch's business. Those books showed income earned from selling goods, but no corresponding expenditures for buying the goods.
Buyers made checks out solely to Hamilton who deposited those checks into her bank account. The couple operated their burglary enterprise for five years before they were caught. The trial court found that Hamilton knew about Welch's illegal activities and was a willing participant in them. The trial court also found that Hamilton knowingly aided Welch's criminal enterprise.
Accordingly, the trial court concluded that Hamilton was responsible for Halberstam's death under both civil conspiracy and aiding and abetting theories. Hamilton appealed to the District of Columbia circuit.
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Get more case briefs explained with Quimbee. Quimbee has over 42,700 case briefs (and counting) keyed to 988 casebooks ► quimbee.com/case-briefs-overview
Halberstam v. Welch - United States Court of Appeals for the District of Columbia Circuit
705 F.2d 472 (1983)
If you help another person commit a tort, can you be held liable to a third party who's injured as a result? We explore that question in Halberstam versus Welch.
Bernard Welch made a living by burglarizing people's homes and selling the stolen goods. Welch had no outside employment and few assets when he met and moved in with Linda Hamilton.
Nevertheless, the couple was able to purchase a million dollar home within a few years. Welch shot and killed Michael Halberstam while burgling Halberstam's home. Elliot Jones Halberstam, Halberstam's wife, sued Welch and Hamilton for Halberstam's wrongful death.
Evidence presented before the trial court established that Welch routinely left the couple's home for several hours during the evenings.
Hamilton claimed that she didn't know what Welch did on his outings. However, Hamilton kept the books for Welch's business. Those books showed income earned from selling goods, but no corresponding expenditures for buying the goods.
Buyers made checks out solely to Hamilton who deposited those checks into her bank account. The couple operated their burglary enterprise for five years before they were caught. The trial court found that Hamilton knew about Welch's illegal activities and was a willing participant in them. The trial court also found that Hamilton knowingly aided Welch's criminal enterprise.
Accordingly, the trial court concluded that Hamilton was responsible for Halberstam's death under both civil conspiracy and aiding and abetting theories. Hamilton appealed to the District of Columbia circuit.
Want more details on this case? Get the rule of law, issues, holding and reasonings, and more case facts here: quimbee.com/cases/halberstam-v-welch
The Quimbee App features over 42,700 case briefs keyed to 988 casebooks. Try it free for 7 days! ► quimbee.com/case-briefs-overview
Have Questions about this Case? Submit your questions and get answers from a real attorney here: quimbee.com/cases/halberstam-v-welch
Did we just become best friends? Stay connected to Quimbee here:
Subscribe to our YouTube Channel ► youtube.com/subscription_center?add_user=QuimbeeDotCom
Quimbee Case Brief App ► quimbee.com/case-briefs-overview
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