Code of Alabama
Ala. Code § 13A-2-23 (2026)
Criminal Liability Based Upon Behavior of Another - Complicity.
✓ official Alabama Legislature (ALISON) text, current July 2026
A person is legally accountable for the behavior of another constituting a criminal offense if, with the intent to promote or assist the commission of the offense:
(1) He procures, induces or causes such other person to commit the offense; or
(2) He aids or abets such other person in committing the offense; or
(3) Having a legal duty to prevent the commission of the offense, he fails to make an effort he is legally required to make.
(Acts 1977, No. 607, p. 812, §415.)
Notes of Decisions
Cited in 102
cases (4 in the last 5 years), 1981–2025 · leading case: Woods v. State, 13 So. 3d 1 (Ala. Crim. App. 2007).
Woods v. State, 13 So. 3d 1 (Ala. Crim. App. 2007). “Woods contends that the evidence was insufficient to sustain his conviction as an accomplice pursuant to § 13A-2-23, Ala.Code 1975. Specifically, he argues that there was no evidence indicating that he possessed or fired a gun during the shooting and that there was no physical…”
Enmund v. Florida, 458 U.S. 782 (1982). “Ala. Code §§ 13A-2-23, 13A-5-40(a)(2), 13A-6-2(a)(1) (1977 and Supp.”
Lewis v. State, 24 So. 3d 480 (Ala. Crim. App. 2007). “1985) (“Alabama Code § 13A-2-23 (1975) continues the long recognized abolition of the distinction between principals and accessories in Alabama.”
C.G. v. State, 841 So. 2d 281 (Ala. Crim. App. 2001). “§ 13A-2-23, Ala.Code 1975. Section 13A-2-23, Ala.”
Tison v. Arizona, 481 U.S. 137 (1987). “030 (1)(b), 200.030(4), 200.033(4)(a)-(b) (1986); N.”
Ex Parte Simmons, 649 So. 2d 1282 (Ala. 1994). “Alabama's complicity statute, § 13A-2-23, provides: "A person is legally accountable for the behavior of another constituting a criminal offense if, with the intent to promote or assist the commission of the offense: "(1) He procures, induces or causes such other person to…”
Travis v. State, 776 So. 2d 819 (Ala. Crim. App. 1997). “§ 13A-5-40(c), Code of Alabama 1975 , states as follows: "A defendant who does not personally commit the act of killing which constitutes the murder is not guilty of a capital offense defined in subsection (a) of this section unless that defendant is legally accountable for the…”
Evans v. State, 508 So. 2d 1205 (Ala. Crim. App. 1987). “See Ala.Code 1975, § 13A-2-23 (Commentary at 39).”
Garrison v. State, 521 So. 2d 997 (Ala. Crim. App. 1987). “"Alabama Code § 13A-2-23 (1975) continues the long recognized abolition of the distinction between principals and accessories in Alabama.”
Brown v. State, 56 So. 3d 729 (Ala. Crim. App. 2009). “1985) (“Alabama Code § 13A-2-23 (1975) continues the long recognized abolition of the distinction between principals and accessories in Alabama.”
Phelps v. State, 439 So. 2d 727 (Ala. Crim. App. 1983). “II Appellant also claims that the indictment was defective for failing to specify that she was charged with complicity, as defined in *734 § 13A-2-23, Code of Alabama 1975. That section provides, in pertinent part, that "A person is legally accountable for the behavior of…”
Haney v. State, 603 So. 2d 368 (Ala. Crim. App. 1991). “In so holding, we necessarily find that the aggravating circumstance was correctly applied to her even though she was the hirer and not the person hired and was convicted of the crime pursuant to the complicity statute, § 13A-2-23. We think the aggravating circumstance should be…”
— Ala. Code § 13A-2-23(1) — 3 cases
Lundy v. State, 539 So. 2d 324 (Ala. Crim. App. 1988).
Ex Parte Simmons, 649 So. 2d 1282 (Ala. 1994). “Alabama's complicity statute, § 13A-2-23, provides: "A person is legally accountable for the behavior of another constituting a criminal offense if, with the intent to promote or assist the commission of the offense: "(1) He procures, induces or causes such other person to…”
DL v. State, 625 So. 2d 1201 (Ala. Crim. App. 1993).
— Ala. Code § 13A-2-23(2) — 16 cases
Dawson v. State, 675 So. 2d 897 (Ala. Crim. App. 1995).
Webb v. State, 696 So. 2d 295 (Ala. Crim. App. 1996).
Lucas v. State, 45 So. 3d 380 (Ala. Crim. App. 2009).
Lawhorn v. State, 574 So. 2d 970 (Ala. Crim. App. 1990).
Morton v. State, 154 So. 3d 1065 (Ala. Crim. App. 2013).
— Ala. Code § 13A-2-23(3) — 8 cases
C.G. v. State, 841 So. 2d 281 (Ala. Crim. App. 2001). “§ 13A-2-23, Ala.Code 1975. Section 13A-2-23, Ala.”
State v. Jackson, 944 P.2d 403 (Wash. Ct. App. 1997).
Ex Parte CG, 841 So. 2d 292 (Ala. 2002).
CG v. State, 841 So. 2d 281 (Ala. Crim. App. 2001).
State of New Jersey Vs. Raquel Ramirez State of New Jersey Vs. Jorge Orozco (14-07-0599, Union Cnty. & Statewide) (record Impounded) (Consol.) (N.J. Super. Ct. App. Div. 2019).
— Ala. Code § 13A-2-23(b) — 3 cases
Diggs v. State, 168 So. 3d 156 (Ala. Crim. App. 2014).
Skinner v. Bevans, 116 So. 3d 1147 (Ala. Civ. App. 2012).
Wallace v. State, 216 So. 3d 464 (Ala. Crim. App. 2015).
— Ala. Code § 13A-2-23(l) — 2 cases
D.L. v. State, 625 So. 2d 1201 (Ala. Crim. App. 1993).
Herring v. State, 540 So. 2d 795 (Ala. Crim. App. 1988).
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