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Torts Keyed to Prosser
Halberstam v. Welch
Citation:
705 F.2d 472 (1983)Facts
Dr. Michael Halberstam was fatally shot by Bernard Welch during a burglary of Halberstam’s home in Washington, D.C. on December 5, 1980. Welch had been conducting numerous burglaries over a five-year period, amassing substantial stolen goods. During this time, Linda Hamilton lived with Welch in an expensive home, typed his business correspondence, kept records of various transactions, and helped dispose of stolen items. Hamilton claimed she believed Welch’s wealth came from his work as an antique dealer, despite numerous suspicious circumstances including late-night outings, lack of regular employment, and the processing of stolen goods in their home. The plaintiff argued that Hamilton’s actions substantially assisted Welch’s criminal enterprise that ultimately led to Halberstam’s death.
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