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Tanaka Criminal Law Casebook

State v. Reeves (1996)

The following case of State v. Reeves analyzes the "substantial step" theory. This theory comes from the MPC and looks at whether a criminal defendant had taken actions that would indicate they would have committed the crime but for* an outside factor that stopped them (such as police intervention).

A similar analysis occurs in United States v. Duran, 96 F.3d 1495 (1996). In that case, the defendant was convicted of attempting to assassinate the President of the United States after he had taken the substantial steps of purchasing a rifle and ammunition, traveling from Colorado to Washington D.C., and standing in front of the White House for several hours with the weapons on his person. Moreover, Duran shot at someone who he believed to be the President–showing criminal intent and purpose. 

While reading the Reeves, pay attention to what you believe are the "substantial steps" taken by the defendant and the criminal intent/purpose.

*Note: we employ the same terminology and analysis as we do when looking at something as a but for cause, but this is not a causation inquiry.