The People of the State of Colorado, Petitioner v. Kenneth Leon Childress, Respondent

Summary

The court held that complicitor liability may apply to a strict-liability offense because the complicitor's own liability is based on the required intent to aid the principal's criminal conduct and awareness of the circumstances constituting the offense. It clarified that the complicitor need not possess the culpable mental state required of the principal, and reversed the court of appeals' vacatur of Childress's vehicular-assault conviction, remanding for consideration of other alleged errors. Chief Justice Rice, concurring in the judgment, would have applied the narrower rationale previously adopted for unintentional offenses without broadly displacing the competing precedent.