Idaho Code

Idaho Code § 19-1430 (2026)

Distinction between accessories and principals abolished. 

✓ current as of May 2026
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Distinction between accessories and principals abolished. 

The distinction between an accessory before the fact and a principal and between principals in the first and second degree, in cases of felony, is abrogated; and all persons concerned in the commission of a felony, whether they directly commit the act constituting the offense, or aid and abet in its commission, though not present, shall hereafter be prosecuted, tried, and punished as principals, and no other facts need be alleged in any indictment against such an accessory than are required in an indictment against his principal.

Notes of Decisions
Cited in 20 cases (1 in the last 5 years), 1950–2021 · leading case: State v. Adamcik, 272 P.3d 417 (Idaho 2012).
State v. Adamcik, 272 P.3d 417 (Idaho 2012). · cites it 20× “Idaho Code § 19-1430 abolishes the distinction between principals and accessories before the fact, providing: The distinction between an accessory before the fact and a principal and between principals in the first[ [11] ] and second[ [12] ] degree, in cases of felony, is…”
State v. Johnson, 188 P.3d 912 (Idaho 2008). · cites it 36× “Idaho Code § 19-1430 and I.C.R. 7(b) are not in conflict.”
Rome v. State, 431 P.3d 242 (Idaho 2018). · cites it 6× “I.C. § 19-1430. Rome is correct that this statute eliminates a distinction between accessories and principals, but the distinction is much narrower than Rome suggests.”
State v. Shackelford, 247 P.3d 582 (Idaho 2010). · cites it 6× “Idaho Code § 19-1430 provides: Distinction between accessories and principals abolished — The distinction between an accessory before the fact and a principal and between principals in the first and second degree, in cases of felony, is abrogated; and all persons concerned in…”
Gonzales v. Duenas-Alvarez, 549 U.S. 183 (2007). · cites it 2× “§§ 702-221, 702-222 (1993); Idaho Code § 19-1430 (Lexis 2004); Ill. Comp.”
State v. Sensenig, 714 P.2d 52 (Idaho Ct. App. 1985). · cites it 8× “Idaho Code § 19-1430 abolishes any distinction between an “accessory before the fact” (one who aids and abets the commission of a crime) and the principal who commits a felony.”
State v. Oldham, 438 P.2d 275 (Idaho 1968). · cites it 4× “I.C. § 19-1430. See State v. Owen, 73 Idaho 394 , 253 P.”
State v. Butcher, 44 P.3d 1180 (Idaho Ct. App. 2002). · cites it 2× “On appeal, Wheeler argued he had not been given notice that he could be found guilty of aiding and abetting the offense.”
State v. Wheeler, 711 P.2d 741 (Idaho Ct. App. 1985). · cites it 4× “By giving the aiding and abetting instructions, the court, according to Wheeler, allowed him to be convicted under an alternative theory against which he had no reason to defend.”
State v. Two Jinn, Inc., 228 P.3d 387 (Idaho Ct. App. 2010). · cites it 6× “The requirements for a charging document for aiding and abetting are governed by I.C. § 19-1430 and I.C.R. 7(b), which appeared to be in conflict.”
State v. Owen, 253 P.2d 203 (Idaho 1953). · cites it 2× “§ 19-1430, I.C., provides: "The distinction between an accessory before the fact and a principal and between principals in the first and second degree, in cases of felony, is abrogated; and all persons concerned in the commission of a felony, whether they directly commit the act…”
State v. Horejs, 141 P.3d 1129 (Idaho Ct. App. 2006). · cites it 2× “Idaho Code § 19-1430 provides: The distinction between an accessory before the fact and a principal and between principals in the first and second degree, in cases of felony, is abrogated; and all persons concerned in the commission of a felony, whether they directly commit the…”
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