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Name: People v. Nuckles
Case #: S200612
Court: CA Supreme Court
District CalSup
Opinion Date: 04/22/2013

One who aids a parolee in absconding from parole supervision is guilty of being an accessory to the underlying felony that was committed by the parolee. Gray was on parole after serving a prison term for dissuading a witness. Nuckles was Gray’s friend. In August of 2009, Gray moved into Nuckles’ house. Nuckles knew he was wanted for violating parole and advised him about avoiding authorities. After Nuckles’ boyfriend informed police of Gray’s presence in their home, Gray was arrested for a parole violation and Nuckles was convicted of being an accessory to Gray’s crime of witness intimidation. On appeal, Nuckles’ claimed that aiding Gray in absconding from parole did not make her an accessory to Gray’s underlying felony. Held: Affirmed. Penal Code section 32 applies to those who help a felon avoid punishment. Nuckles intentionally helped Gray avoid a part of his punishment for dissuading a witness, i.e., his parole supervision. Thus, there was a sufficient nexus between Gray’s underlying offense and Nuckles’ aid to render her an accessory.