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). “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). “Idaho Code § 19-1430 and I.C.R. 7(b) are not in conflict.”
Rome v. State, 431 P.3d 242 (Idaho 2018). “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). “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). “§§ 702-221, 702-222 (1993); Idaho Code § 19-1430 (Lexis 2004); Ill. Comp.”
State v. Sensenig, 714 P.2d 52 (Idaho Ct. App. 1985). “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). “I.C. § 19-1430. See State v. Owen, 73 Idaho 394 , 253 P.”
State v. Butcher, 44 P.3d 1180 (Idaho Ct. App. 2002). “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). “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). “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). “§ 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). “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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