Colorado Revised Statutes

Colo. Rev. Stat. § 18-1-601 (2026)

Liability based upon behavior

✓ current as of July 2026
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A person is guilty of an offense if it is committed by the behavior of another person for which he is legally accountable as provided in sections 18-1-602 to 18-1-607.

Source: L. 71: R&RE, p. 406, § 1. C.R.S. 1963: § 40-1-701.

Notes of Decisions
Cited in 13 cases, 1977–2017 · leading case: People v. R. V., 635 P.2d 892 (Colo. 1981).
People v. R. V., 635 P.2d 892 (Colo. 1981). · cites it 16× “" Section 18-1-601, C.R.S.1973. Our statute defining the various culpable mental states is expressly made applicable to "offenses.”
Gonzales v. Duenas-Alvarez, 549 U.S. 183 (2007). · cites it 2× “§§ 5-2-402, 5-2-03(a) (2006); Colo.Rev.Stat. Ann. §§ 18-1-601, 18-1-603 (2006); Conn.”
People v. Childress, 2015 CO 65 (Colo. 2015). · cites it 4× “§ 18-1-601, C.R.S. (2015). Part 6 then makes a person legally accountable for the behavior of an innocent person if he acts with the culpable mental state sufficient for the commission of an offense and causes that innocent person to engage in behavior sufficient for commission…”
People v. Marquez, 692 P.2d 1089 (Colo. 1984). · cites it 4× “A person is legally accountable for the behavior of another constituting a criminal offense if, with the intent to promote or facilitate the commission of the offense, he aids, abets, or advises such other person in planning or committing the offense.”
Montoya v. People, 394 P.3d 676 (Colo. 2017). “In addition to eliminating any distinction among what formerly had been principals in the first and second degree and accessories before the fact, based on the Model Penal Code concept of “complicity,” see §§ 18-1-601 to -603, C.R.S. (2016); Childress, ¶ 7, 363 P.”
People v. Hall, 60 P.3d 728 (Colo. Ct. App. 2002). · cites it 2× “However, one also may be held accountable as a complicitor under § 18-1-601, C.R.S.2001, which provides that “[a] person is guilty of an offense if it is committed by the behavior of another person for which he [or she] is legally accountable as provided in sections 18-1-602 to…”
People v. Allee, 740 P.2d 1 (Colo. 1987). “Section 18-1-605 provides: In any prosecution for an offense in which criminal liability is based upon the behavior of another pursuant to sections 18-1-601 to 18-1-604, it is no defense that the other person has not been prosecuted for or convicted of any offense based upon the…”
People v. Calvaresi, 600 P.2d 57 (Colo. 1979). “*326 The trial court gave an instruction consistent with sections 18-1-601 and 18-1-603, C.R.S. 1973.”
People v. Childress, 2015 CO 65 (Colo. 2015). · cites it 2× “§ 18-1-601, C.R.S. (2015). Part 6 then makes a person legally accountable for the behavior of an innocent person if he acts with the culpable mental state sufficient for the commission of an offense and causes that innocent person to engage in behavior sufficient for commission…”
People v. Marcy, 628 P.2d 69 (Colo. 1981). · cites it 3× “Section 18-1-601(6), C.R.S.1973 (1978 Repl.”
People v. R. V., 606 P.2d 1311 (Colo. Ct. App. 1980). · cites it 3× “” Section 18-1-601, C.R.S.1973 (1978 Repl. Vol.”
People v. Cornell, 572 P.2d 137 (Colo. 1977). · cites it 2× “1 and the accountability statutes, section 18-1-601, et seq,, C.R.S. 1973, to be applied to a patient of a state mental institution who aids another patient’s escape.”
— Colo. Rev. Stat. § 18-1-601(6) — 1 case
People v. Marcy, 628 P.2d 69 (Colo. 1981). “Section 18-1-601(6), C.R.S.1973 (1978 Repl.”
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