In Rice v. Paladin Enterprises, Inc., 128 F.3d 233, 251 (4th Cir. 1997), cert. denied, 523 U.S. 1074 (1998), the Fourth Circuit held that a publisher of a "murder for hire" manual that was used by a "hit man" who committed a murder could be held liable in tort for aiding and abetting the murderer.
In reversing a grant of summary judgment in favor of the publisher, the court stated:
The primary, and possibly only, difference between Maryland's civil and criminal laws of aiding and abetting is the intent requirement. As Judge Learned Hand explained in discussing generally the difference between civil and criminal aiding and abetting laws, the intent standard in the civil tort context requires only that the criminal conduct be the "natural consequence of one's original act," whereas criminal intent to aid and abet requires that the defendant have a "purposive attitude" toward the commission of the offense. United States v. Peoni, 100 F.2d 401, 402 (2d Cir. 1938) , . . . We assume that Maryland prescribes a higher intent standard for the imposition of criminal liability than it does for civil liability. (Id. at 251.)