Though relatively rare, “aiding and abetting” can also result in civil liability. In Missouri, for harm resulting to a third person from the tortious conduct of another, one is subject to liability if he or she knows that the other’s conduct contitutes a breach of duty and gives substantial assistance or encouragement to the other. Bradley v. Ray, 904 S.W.2d 302, 315 (Mo. Ct. App. 1995). The first notable case to discuss this claim was Shelter Mut. Ins. Co. v. White, 930 S.W.2d 1, 3-4 (Mo. Ct. App. 1996). In Shelter, the court found that there was a claim for aiding and abetting negligence against passengers in a car who actively encouraged an intoxicated driver to drive fast and disobey traffic signs. Id.at 5.
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