Ariz. Rev. Stat. » Title 13
Arizona Revised Statutes

Ariz. Rev. Stat. § 13-203 (2026)

Causal relationship between conduct and result; relationship to mental culpability

✓ current as of May 2026
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A. Conduct is the cause of a result when both of the following exist:

1. But for the conduct the result in question would not have occurred.

2. The relationship between the conduct and result satisfies any additional causal requirements imposed by the statute defining the offense.

B. If intentionally causing a particular result is an element of an offense, and the actual result is not within the intention or contemplation of the person, that element is established if:

1. The actual result differs from that intended or contemplated only in the respect that a different person or different property is injured or affected or that the injury or harm intended or contemplated would have been more serious or extensive than that caused; or

2. The actual result involves similar injury or harm as that intended or contemplated and occurs in a manner which the person knows or should know is rendered substantially more probable by such person's conduct.

C. If recklessly or negligently causing a particular result is an element of an offense, and the actual result is not within the risk of which the person is aware or in the case of criminal negligence, of which the person should be aware, that element is established if:

1. The actual result differs from the probable result only in the respect that a different person or different property is injured or affected or that the injury or harm intended or contemplated would have been more serious or extensive than that caused; or

2. The actual result involves similar injury or harm as the probable result and occurs in a manner which the person knows or should know is rendered substantially more probable by such person's conduct.

Notes of Decisions
Cited in 35 cases (8 in the last 5 years), 1982–2026 · leading case: State v. Johnson, 72 P.3d 343 (Ariz. Ct. App. 2003).
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State v. Johnson, 72 P.3d 343 (Ariz. Ct. App. 2003). · cites it 24× “The State’s primary theory was that Johnson’s intent in filing the shot that injured Officer D could be “transferred” to provide the requisite intent for assault on the bystanders. Johnson objected to the instruction.”
State v. Cocio, 709 P.2d 1336 (Ariz. 1985). · cites it 20× “A.R.S. § 13-203 reads in relevant part: "§ 13-203.”
State v. Siner, 69 P.3d 1022 (Ariz. Ct. App. 2003). · cites it 13× “” But we conclude that this prohibited act constitutes “conduct” rather than a “result” as these words are used in A.R.S. § 13-203 (2001). This distinction between “conduct” and “result” is emphasized by the legislature’s use of these words in § 13-203(A), the subsection…”
State v. Cantua-Ramirez, 718 P.2d 1030 (Ariz. Ct. App. 1986). · cites it 10× “The actual result differs from that intended or contemplated only in the respect that a different person or different property is injured or affected or that the injury or harm intended or contemplated would have been more serious or extensive than that caused____ The…”
State of Arizona v. Jesus Xavier Almaguer, 303 P.3d 84 (Ariz. Ct. App. 2013). · cites it 4× “See AR.S. § 13-203(0(2). Almaguer’s version of the facts did not place causation at issue, and the jury would not have been aided by a proximate-cause instruction.”
State v. Rodriguez-Gonzales, 790 P.2d 287 (Ariz. Ct. App. 1990). · cites it 6× “A.R.S. § 13-203(B). Arizona’s legislature has seen fit to codify the doctrine of transferred intent and to extend that doctrine to intentional criminal conduct causing an unintended result.”
State v. Amaya-Ruiz, 800 P.2d 1260 (Ariz. 1990). · cites it 2× “See A.R.S. § 13-203(B), (C). The court gave the instructions over defendant’s objection.”
State v. Lawson, 698 P.2d 1266 (Ariz. 1985). · cites it 4× “The "but for" standard, as defined in A.R.S. § 13-203, was not intended to supersede prior case law but instead to be consistent with the proximate cause analysis as enunciated in State v.”
State v. Williams, 854 P.2d 131 (Ariz. 1993). · cites it 2× “See A.R.S. § 13-203(B). *102 We must distinguish between the culpable mental state required for the commission of the offense, which is defined by the listed crimes in § 13-604.”
State v. Gunter, 643 P.2d 1034 (Ariz. Ct. App. 1982). · cites it 4× “Such a focus in our opinion ignores the doctrine of transferred intent, now codified in A.R.S. § 13-203(B). 4 We therefore hold that the constitutional prohibition against placing a person in double jeopardy is not violated under the facts here by charging and punishing the…”
State Ex Rel. Napolitano v. Gravano, 60 P.3d 246 (Ariz. Ct. App. 2002). · cites it 3× “The phrase “caused by” involves a causal relationship between conduct and result, which A.R.S. § 13-203(A) (2001) explains as follows: A.”
State v. Henley, 687 P.2d 1220 (Ariz. 1984). · cites it 2× “A.R.S. § 13-203. This statute essentially codifies the common law concept of transferred intent.”
Show all 35 citing cases →
— Ariz. Rev. Stat. § 13-203(A) — 10 cases
State v. Far West Water & Sewer Inc., 228 P.3d 909 (Ariz. Ct. App. 2010).
State Ex Rel. Napolitano v. Gravano, 60 P.3d 246 (Ariz. Ct. App. 2002). “The phrase “caused by” involves a causal relationship between conduct and result, which A.R.S. § 13-203(A) (2001) explains as follows: A.”
State v. Siner, 69 P.3d 1022 (Ariz. Ct. App. 2003). “” But we conclude that this prohibited act constitutes “conduct” rather than a “result” as these words are used in A.R.S. § 13-203 (2001). This distinction between “conduct” and “result” is emphasized by the legislature’s use of these words in § 13-203(A), the subsection…”
State of Arizona v. Manuel Jesus Pesqueira, 333 P.3d 797 (Ariz. Ct. App. 2014).
State of Arizona v. Hon. aragon/max Fontes (Ariz. 2022).
— Ariz. Rev. Stat. § 13-203(A)(1) — 7 cases
State v. Marty, 801 P.2d 468 (Ariz. Ct. App. 1990).
State Ex Rel. Napolitano v. Gravano, 60 P.3d 246 (Ariz. Ct. App. 2002). “The phrase “caused by” involves a causal relationship between conduct and result, which A.R.S. § 13-203(A) (2001) explains as follows: A.”
State v. Sommerfield (Ariz. Ct. App. 2017).
State of Arizona v. Bryan Wayne Hulsey (Ariz. 2018).
State v. Etienne (Ariz. Ct. App. 2022).
— Ariz. Rev. Stat. § 13-203(B) — 9 cases
State v. Johnson, 72 P.3d 343 (Ariz. Ct. App. 2003). “The State’s primary theory was that Johnson’s intent in filing the shot that injured Officer D could be “transferred” to provide the requisite intent for assault on the bystanders. Johnson objected to the instruction.”
State v. Siner, 69 P.3d 1022 (Ariz. Ct. App. 2003). “” But we conclude that this prohibited act constitutes “conduct” rather than a “result” as these words are used in A.R.S. § 13-203 (2001). This distinction between “conduct” and “result” is emphasized by the legislature’s use of these words in § 13-203(A), the subsection…”
State v. Amaya-Ruiz, 800 P.2d 1260 (Ariz. 1990). “See A.R.S. § 13-203(B), (C). The court gave the instructions over defendant’s objection.”
State v. Williams, 854 P.2d 131 (Ariz. 1993). “See A.R.S. § 13-203(B). *102 We must distinguish between the culpable mental state required for the commission of the offense, which is defined by the listed crimes in § 13-604.”
State v. Gunter, 643 P.2d 1034 (Ariz. Ct. App. 1982). “Such a focus in our opinion ignores the doctrine of transferred intent, now codified in A.R.S. § 13-203(B). 4 We therefore hold that the constitutional prohibition against placing a person in double jeopardy is not violated under the facts here by charging and punishing the…”
— Ariz. Rev. Stat. § 13-203(B)(1) — 4 cases
State v. Johnson, 72 P.3d 343 (Ariz. Ct. App. 2003). “The State’s primary theory was that Johnson’s intent in filing the shot that injured Officer D could be “transferred” to provide the requisite intent for assault on the bystanders. Johnson objected to the instruction.”
State v. Cantua-Ramirez, 718 P.2d 1030 (Ariz. Ct. App. 1986). “The actual result differs from that intended or contemplated only in the respect that a different person or different property is injured or affected or that the injury or harm intended or contemplated would have been more serious or extensive than that caused____ The…”
State v. Rodriguez-Gonzales, 790 P.2d 287 (Ariz. Ct. App. 1990). “A.R.S. § 13-203(B). Arizona’s legislature has seen fit to codify the doctrine of transferred intent and to extend that doctrine to intentional criminal conduct causing an unintended result.”
State v. Allen (Ariz. Ct. App. 2018).
— Ariz. Rev. Stat. § 13-203(B)(2) — 2 cases
State v. Johnson, 72 P.3d 343 (Ariz. Ct. App. 2003). “The State’s primary theory was that Johnson’s intent in filing the shot that injured Officer D could be “transferred” to provide the requisite intent for assault on the bystanders. Johnson objected to the instruction.”
In re the Appeal in Pima Cnty., Juv. Action No. J-78539-2, 693 P.2d 950 (Ariz. Ct. App. 1984).
— Ariz. Rev. Stat. § 13-203(B)(2001) — 1 case
State v. Siner, 69 P.3d 1022 (Ariz. Ct. App. 2003). “” But we conclude that this prohibited act constitutes “conduct” rather than a “result” as these words are used in A.R.S. § 13-203 (2001). This distinction between “conduct” and “result” is emphasized by the legislature’s use of these words in § 13-203(A), the subsection…”
— Ariz. Rev. Stat. § 13-203(C) — 2 cases
State v. Cantua-Ramirez, 718 P.2d 1030 (Ariz. Ct. App. 1986). “The actual result differs from that intended or contemplated only in the respect that a different person or different property is injured or affected or that the injury or harm intended or contemplated would have been more serious or extensive than that caused____ The…”
State v. Lopez, 323 P.3d 748 (Ariz. Ct. App. 2014).
— Ariz. Rev. Stat. § 13-203(C)(2) — 4 cases
State v. Cocio, 709 P.2d 1336 (Ariz. 1985). “A.R.S. § 13-203 reads in relevant part: "§ 13-203.”
State of Arizona v. Jesus Xavier Almaguer, 303 P.3d 84 (Ariz. Ct. App. 2013). “See AR.S. § 13-203(0(2). Almaguer’s version of the facts did not place causation at issue, and the jury would not have been aided by a proximate-cause instruction.”
Robertson v. Commonwealth, 82 S.W.3d 832 (Ky. 2002).
State of Arizona v. Anthony Eugene Searight (Ariz. Ct. App. 2026).
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