Supreme Court of Colorado

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

November 23, 2015363 P.3d 155

Summary

The court held that complicitor liability may apply to a strict-liability offense because the complicitor's own liability is not strict liability and instead requires intent to aid the principal's criminal conduct plus awareness of the circumstances necessary to constitute the offense. It therefore reversed the court of appeals' judgment vacating Childress's vehicular-assault conviction and remanded for consideration of the adequacy and effect of the jury instructions and any remaining assignments of error. Chief Justice Rice, concurring in the judgment, would have applied the existing rule more narrowly and declined to unsettle prior precedent beyond the strict-liability issue presented.