Code of Alabama
Ala. Code § 13A-2-20 (2026)
Criminal Liability Based Upon Behavior.
✓ official Alabama Legislature (ALISON) text, current July 2026
A person is criminally liable for an offense if it is committed by his own behavior or by the behavior of another person for which he is legally accountable as provided for in this article, or both.
(Acts 1977, No. 607, p. 812, §401.)
Notes of Decisions
Cited in 16
cases (1 in the last 5 years), 1983–2025 · leading case: Gonzales v. Duenas-Alvarez, 549 U.S. 183 (2007).
Gonzales v. Duenas-Alvarez, 549 U.S. 183 (2007). “§§ 5-2-402, 5-2-03(a) (2006); Colo.Rev.Stat. Ann. §§ 18-1-601, 18-1-603 (2006); Conn.”
Deutcsh v. State, 610 So. 2d 1212 (Ala. Crim. App. 1992). “At trial those facts were presented to the jury in a disorganized and jumbled fashion which may have been due, at least partially, to the very nature of the alleged offense.”
Price v. State, 725 So. 2d 1003 (Ala. Crim. App. 1997). “The appellant appears to believe that, if he intended to kill the victim, but did not actually participate in *1055 the killing, remaining only an observer who was there to render aid if the need arose, and actively participated in only the robbery, he would be guilty of…”
Garrison v. State, 521 So. 2d 997 (Ala. Crim. App. 1987). “See Alabama Code §§ 13A-2-20 and -23 (1975) (Commentary).”
Smith v. State, 795 So. 2d 788 (Ala. Crim. App. 2000). “2d 1003, 1055 (Ala.Cr.App.1997), aff'd, 725 So.2d 1063 (Ala.”
McWhorter v. State, 781 So. 2d 257 (Ala. Crim. App. 1999). “This Court disposed of the appellant's argument as follows: "The appellant appears to believe that, if he intended to kill the victim, but did not actually participate in the killing, remaining only an observer who was there to render aid if the need arose, and actively…”
Gamble v. State, 791 So. 2d 409 (Ala. Crim. App. 2000). “2d 1012 (1999) (citations omitted); see also §§ 13A-2-20 through 13A-2-23 and 13A-5-40(c), Ala.”
State v. Sowell, 728 A.2d 712 (Md. 1999). “2d 284, 290 (1950); Ala.Code § 13A-2-20 (1994) & Commentary (“In effect, this [section abrogates] the distinction which was once drawn between principals and accessories.”
Gaston v. State, 265 So. 3d 387 (Ala. Crim. App. 2018). “of this opinion, supra , the evidence was sufficient to allow the jury to conclude beyond a reasonable doubt that Gaston aided and abetted Tyrone Thompson and Nicholas Smith in killing Kevin Thompson.”
Apicella v. State, 809 So. 2d 841 (Ala. Crim. App. 2000). “In addressing an argument similar to Apicella's, this Court recently stated: "`The appellant appears to believe that, if he intended to kill the victim, but did not actually participate in the killing, remaining only an observer who was there to render aid if the need arose, and…”
Ex Parte Howell, 431 So. 2d 1328 (Ala. 1983). “Under the Alabama Criminal Code a person may be criminally liable based upon his own behavior, Code 1975, § 13A-2-20, or based upon the behavior of another, §§ 13A-2-21 through -23.”
Summit Med. Assocs., P.C. v. James, 984 F. Supp. 1404 (M.D. Ala. 1998). “§ 13A-2-20) (Michie 1994). 34 .Although one could argue that § 26-22-3(a) of the post-viability abortion statute only conditions liability on a finding that the physician had the requisite mens rea regarding the fact that he or she was performing an abortion, and not regarding…”
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