California, United States of America
The following excerpt is from The People v. Tovias, 91 Cal.Rptr.2d 396 (Cal. App. 1999):
8 In one opinion, the Second District held in 1931 that the defendant's 14-year-old and 16-year-old daughters who had participated in acts of incest were not accomplices because they could not be tried as adults but only in juvenile court and therefore were not subject to prosecution on the same charge as the defendant. (People v. Johnson (1931) 115 Cal.App. 704, 706-707.) On that invalid theory, no minor could ever be an accomplice to any crime.
8 In one opinion, the Second District held in 1931 that the defendant's 14-year-old and 16-year-old daughters who had participated in acts of incest were not accomplices because they could not be tried as adults but only in juvenile court and therefore were not subject to prosecution on the same charge as the defendant. (People v. Johnson (1931) 115 Cal.App. 704, 706-707.) On that invalid theory, no minor could ever be an accomplice to any crime.
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