UNITED STATES OF AMERICA v. SCOTT STEWARD CAMMORTO
US Court of Appeals for the Fourth Circuit, Niemeyer, June 13, 2017,
Sentencing- Because aiding and abetting makes you culpable under both Georgia and federal law, a conviction under Georgia’s rape law is the same as a conviction under the federal Aggravated sexual abuse.

Facts: In 1999, Cammorto pled guilty in Georgia to rape and kidnapping and was sentenced to 15 years imprisonment. Upon release, Cammorto was requried to register as a sex offender under the federal Sex Offender Registration and Notification Act (“SORNA”).
In 2015, Virginia authorities responding to a domestic violence call found that Cammorto was living in Virginia without having notified Georgia or Virginia authorities that he had moved.
Cammorto was charged and convicted of failing to update his sex-offender registration. At sentencing, he was sentenced as if he was convicted of the equivalent of federal rape charges.
Cammorto appealed, arguing that Georgia’s rape statute was not as severe as the federal Aggravated sexual abuse statute because under the Georgia statute you could be convicted if you aided or abetted the rape (even if you did not physically participate).

Held: The Fourth Circuit disagreed. Aiding and abetting is not a separate crime; it’s a way to be culpable for a crime. Moreover, the law in Georgia regarding aiding and abetting is the same as the federal law. Aiding and abetting a felony makes you liable for the felony.

Aiding and Abetting – Under federal law (as well as Georgia law, Maryland law, and the law of many other states), someone who aids and abets an individual committing a crime is also culpable for the crime.

Note: Under Maryland Law, however, it depends on whether the person was assisting/encouraging the in-progress crime (which would make them a principal) or was encouraging a future crime (which could make them an accomplice before the fact)