Greiner v. State
In Greiner v. State, 741 P.2d 662 (Alaska App. 1987), the Court held that "evidence that codefendants were willing to sell drugs and were well-acquainted and cooperated with each other in the individual sale of drugs" was an insufficient ground for joinder because there was "no real evidence" of a joint venture.
In amending Rule 8(b) the legislature stated that this amendment "allows a tacit joint venture to be proven by circumstantial evidence." It appears that the legislature intended this amendment to promote the joinder of claims, and make it easier to come within the definition of 8(b).