At the trial level, Peoni was convicted as an accomplice to Dorsey's possession of the counterfeit bills.

[4] In an opinion by Judge Learned Hand, the Second Circuit reversed Peoni's conviction.

§ 2),[5] which punished anyone who "aids, abets, counsels, commands, induces, or procures" the commission of a crime.

Peoni had no purpose regarding Dorsey's possession because Regno was free to do whatever he wanted with the bills.

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