Uploaded April 2025 | Updated September 2026, 3 weeks ago
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State v. Anthony
New Hampshire Supreme Court
861 A.2d 773 (2004)
A person who helps another person commit a crime may be criminally liable as an accomplice.
In State versus Anthony, the court considered whether a defendant could be convicted as an accomplice to a negligence crime.
Virginia Anthony allegedly helped her husband bind a cult's four legs together. The cult's efforts to free itself caused it pain and injury. Anthony was indicted on a felony charge of cruelty to animals.
At Anthony's trial, the trial court instructed the jury on the lesser included offense of accomplice to negligent cruelty to animals. The jury acquitted Anthony of the felony charge, but found her guilty of the lesser included offense.
Anthony appealed to the New Hampshire Supreme Court, arguing that New Hampshire law didn't recognize the crime of accomplice to negligent cruelty to animals.
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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
State v. Anthony
New Hampshire Supreme Court
861 A.2d 773 (2004)
A person who helps another person commit a crime may be criminally liable as an accomplice.
In State versus Anthony, the court considered whether a defendant could be convicted as an accomplice to a negligence crime.
Virginia Anthony allegedly helped her husband bind a cult's four legs together. The cult's efforts to free itself caused it pain and injury. Anthony was indicted on a felony charge of cruelty to animals.
At Anthony's trial, the trial court instructed the jury on the lesser included offense of accomplice to negligent cruelty to animals. The jury acquitted Anthony of the felony charge, but found her guilty of the lesser included offense.
Anthony appealed to the New Hampshire Supreme Court, arguing that New Hampshire law didn't recognize the crime of accomplice to negligent cruelty to animals.
Want more details on this case? Get the rule of law, issues, holding and reasonings, and more case facts here: quimbee.com/cases/state-v-anthony
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![Atkinson Trading Co v Shirley teaser Case Brief Summary | Law Case Explained
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Atkinson Trading Co. v. Shirley | 532 U.S. 645 (2001)
In Atkinson Trading Company versus Shirley, well see whether an Indian tribe can impose a tax on non member hotel guests who stay on non Indian fee land within the tribes reservation.
In nineteen sixteen, Hubert Richardson purchased land in Arizona from the United States government and built the Cameron Trading Post. In nineteen thirty four, the boundaries of the Navajo Nation reservation expanded, which brought the trading post into the reservation boundaries.
However, Richardson still owned his land in fee. Over time, Richardson also built a hotel and restaurant at the trading post. Atkinson Trading Company later became the owner of the property.
In nineteen ninety two, the Navajo Nation enacted an eight percent hotel occupancy tax for all hotels located within the reservations boundaries.
Hotel guests had a legal responsibility to pay the tax. However, hotel owners had to collect the tax from the guests and submit the revenue to the Navajo tax commission. The Cameron Trading Post Hotel paid about eighty four thousand dollars of hotel taxes every year.
Atkinson challenged the tribes authority to impose the tax under the United States Supreme Courts holding in Montana versus United States.
In Montana, the court held that Indian tribes dont have civil authority over nonmembers on non Indian land within a reservation unless the nonmembers entered into a consensual relationship with the tribe or a nonIndians conduct on the non Indian land threatens or affects the tribes political integrity, economic security, or health or welfare.
A tribes civil authority includes its ability to tax nonmembers. The Navajo tax commission and the Navajo supreme court rejected Atkinsons challenge to the hotel tax. Atkinson then sued Navajo tax commission members, including Joe Shirley in district court. The district court upheld the tax. Atkinson appealed, but the court of appeals affirmed the district courts holding. The court of appeals held that the hotel tax fell under the first Montana exception.
The court found that there was a consensual relationship between nonmember guests and the tribe because guests could stay off reservation and not pay the tax.
Also, the tribe provided certain services to the hotel and its guests, such as tribal police, fire, and medical services. Atkinson appealed again, and the United States Supreme Court granted cert.
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#casebriefs #lawcases #casesummaries Atkinson Trading Co v Shirley teaser Case Brief Summary | Law Case Explained](https://i.ytimg.com/vi/xLQoCV9flXI/mqdefault.jpg)



