Oaks v. People

Oaks was separately charged, tried and convicted of murder in the first degree, the jury fixing his punishment at life imprisonment. At his trial the People introduced into evidence exhibit P, which was a thirty-three page, typewritten, question-and-answer type statement of Beaty. In this statement Beaty stated, among many, many other things, that he shot and killed one Straub in an attempted robbery and went on to describe how Oaks was not only present and assisting him in the robbery but had actually planned and in fact "ordered" its commission. In this same statement Beaty under questioning also related in great detail the nature of his association with Oaks, and in so doing disclosed that he had committed numerous other crimes, mostly of a petty nature and totally unrelated to the charge of murder, but all committed at the urging of Oaks. Exhibit P was given by Beaty out of the presence of Oaks, and there is nothing in the record to indicate that Oaks even knew of its contents, let alone that he assented thereto. Over a timely objection Peoples exhibit P was received in evidence in its entirety, the trial court instructing the jury that before Oaks could be convicted as an accessory to the crime of murder in the first degree, the People must first prove beyond a reasonable doubt that Beaty as the principal was himself guilty of first degree murder, and that this statement was to be considered by the jury only in determining whether Beaty was guilty as a principal of murder in the first degree.