Wash. Rev. Code » Title 9A · Chapter 9A.08
Revised Code of Washington

Wash. Rev. Code § 9A.08.020 (2026)

✓ current as of May 2026
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(1) A person is guilty of a crime if it is committed by the conduct of another person for which he or she is legally accountable.
(2) A person is legally accountable for the conduct of another person when:
(a) Acting with the kind of culpability that is sufficient for the commission of the crime, he or she causes an innocent or irresponsible person to engage in such conduct; or
(b) He or she is made accountable for the conduct of such other person by this title or by the law defining the crime; or
(c) He or she is an accomplice of such other person in the commission of the crime.
(3) A person is an accomplice of another person in the commission of a crime if:
(a) With knowledge that it will promote or facilitate the commission of the crime, he or she:
(i) Solicits, commands, encourages, or requests such other person to commit it; or
(ii) Aids or agrees to aid such other person in planning or committing it; or
(b) His or her conduct is expressly declared by law to establish his or her complicity.
(4) A person who is legally incapable of committing a particular crime himself or herself may be guilty thereof if it is committed by the conduct of another person for which he or she is legally accountable, unless such liability is inconsistent with the purpose of the provision establishing his or her incapacity.
(5) Unless otherwise provided by this title or by the law defining the crime, a person is not an accomplice in a crime committed by another person if:
(a) He or she is a victim of that crime; or
(b) He or she terminates his or her complicity prior to the commission of the crime, and either gives timely warning to the law enforcement authorities or otherwise makes a good faith effort to prevent the commission of the crime.
(6) A person legally accountable for the conduct of another person may be convicted on proof of the commission of the crime and of his or her complicity therein, though the person claimed to have committed the crime has not been prosecuted or convicted or has been convicted of a different crime or degree of crime or has an immunity to prosecution or conviction or has been acquitted.
[ 2011 c 336 s 351; 1975-'76 2nd ex.s. c 38 s 1; 1975 1st ex.s. c 260 s 9A.08.020.]

Notes:

Effective date—1975-'76 2nd ex.s. c 38: "This 1976 amendatory act is necessary for the immediate preservation of the public peace, health, and safety, the support of the state government and its existing public institutions, and shall take effect on July 1, 1976." [1975-'76 2nd ex.s. c 38 s 21.]
Severability—1975-'76 2nd ex.s. c 38: "If any provision of this 1976 amendatory act, or its application to any person or circumstance is held invalid, the remainder of the act, or the application of the provision to other persons or circumstances is not affected." [1975-'76 2nd ex.s. c 38 s 20.]
Notes of Decisions
Cited in 415 cases (58 in the last 5 years), 1976–2026 · leading case: City of Auburn v. Hedlund, 201 P.3d 315 (Wash. 2009).
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City of Auburn v. Hedlund, 201 P.3d 315 (Wash. 2009). · cites it 20× “At the close of the city of Auburn's case in chief, the trial court dismissed the DUI and reckless driving charges because a victim may not be charged as an accomplice under RCW 9A.08.020. We recognize that the legislature may have intended a more limited application of the…”
City of Auburn v. Hedlund, 165 Wash. 2d 645 (Wash. 2009). · cites it 17× “At the close of the city of Auburn’s case in chief, the trial court dismissed the DUI and reckless driving charges because a victim may not be charged as an accomplice under RCW 9A.08.020. We recognize that the legislature may have intended a more limited application of the…”
State v. Jackson, 976 P.2d 1229 (Wash. 1999). · cites it 15× “The defendants respond that the instruction was erroneous because Washington’s accomplice liability statute, RCW 9A.08.020, does not impose liability on an individual for failing to perform a legal duty.”
State v. Stein, 27 P.3d 184 (Wash. 2001). · cites it 8× “RCW 9A.08.020. In contrast, the conspiracy statute provides that: A person is guilty of criminal conspiracy when, with intent that conduct constituting a crime be performed, he or she agrees with one or more persons to engage in or cause the performance of such conduct, and any…”
State v. Stein, 144 Wash. 2d 236 (Wash. 2001). · cites it 8× “RCW 9A.08.020. In contrast, the conspiracy statute provides that: A person is guilty of criminal conspiracy when, with intent that conduct constituting a crime be performed, he or she agrees with one or more persons to engage in or cause the performance of such conduct, and any…”
State v. Bauer, 329 P.3d 67 (Wash. 2014). · cites it 15× “The two-member majority also held that the facts of the case did not preclude the State from seeking to convict Bauer under the complicity statute, RCW 9A.08.020. Id. at 77 . The majority rejected Bauer’s vagueness argument.”
State v. Roberts, 14 P.3d 713 (Wash. 2000). · cites it 9× “The accomplice liability statute requires only a mens rea of knowledge, and an actus reus of soliciting, commanding, encouraging, or requesting the commission of the crime, or aiding or agreeing to aid in the planning of the crime.”
State v. Davis, 682 P.2d 883 (Wash. 1984). · cites it 12× “II It is clear from the plain meaning of the language in the accomplice liability statute, RCW 9A.08.020, that an accomplice to an armed robbery must know that a weapon is involved in order to be convicted as an accomplice to first degree robbery.”
United States v. Jose Valdivia-Flores, 876 F.3d 1201 (9th Cir. 2017). · cites it 6× “Noticeably, no evidence in the record refers to Wash. Rev. Code § 9A.08.020 or suggests that Valdivia-Flores was convicted as an accomplice.”
Waddington v. Sarausad, 555 U.S. 179 (2009). · cites it 5× “” Wash. Rev. Code §§9A.08.020(1)–(3) (2008) (internal number ing omitted).”
In Re Domingo, 119 P.3d 816 (Wash. 2006). · cites it 10× “Duffy, Attorney at Law, Michael C. Kinnie, Attorney at Law, Philip A. Meyers, Attorney at Law, Robert W.”
State v. Cronin, 14 P.3d 752 (Wash. 2000). · cites it 8× “" It is their position that under our state's complicity statute, RCW 9A.08.020, a person is not culpable as an accomplice unless that person possesses general knowledge of the specific crime with which he or she is eventually charged.”
Show all 415 citing cases →
— Wash. Rev. Code § 9A.08.020(1) — 51 cases
State v. McKim, 653 P.2d 1040 (Wash. 1982).
State v. Silva-Baltazar, 886 P.2d 138 (Wash. 1994).
State v. Davis, 682 P.2d 883 (Wash. 1984). “II It is clear from the plain meaning of the language in the accomplice liability statute, RCW 9A.08.020, that an accomplice to an armed robbery must know that a weapon is involved in order to be convicted as an accomplice to first degree robbery.”
State v. Kwan Fai Mak, 718 P.2d 407 (Wash. 1986).
State v. Farnsworth, 374 P.3d 1152 (Wash. 2016).
— Wash. Rev. Code § 9A.08.020(2) — 4 cases
McKenzy Alfred v. Merrick Garland, 64 F.4th 1025 (9th Cir. 2023).
State v. Early, 674 P.2d 179 (Wash. Ct. App. 1983).
State of Washington v. Antonio Jose Torres (Wash. Ct. App. 2020).
State v. Bauer (Wash. 2014).
— Wash. Rev. Code § 9A.08.020(2)(a) — 15 cases
State v. Bauer, 329 P.3d 67 (Wash. 2014). “The two-member majority also held that the facts of the case did not preclude the State from seeking to convict Bauer under the complicity statute, RCW 9A.08.020. Id. at 77 . The majority rejected Bauer’s vagueness argument.”
State v. Bobenhouse, 214 P.3d 907 (Wash. 2009).
State v. Bobenhouse, 166 Wash. 2d 881 (Wash. 2009).
State v. Bobenhouse, 143 Wash. App. 315 (Wash. Ct. App. 2008).
State v. Bobenhouse, 177 P.3d 209 (Wash. Ct. App. 2008).
— Wash. Rev. Code § 9A.08.020(2)(a)(i) — 1 case
State Of Washington v. Roderic Barrington (Wash. Ct. App. 2018).
— Wash. Rev. Code § 9A.08.020(2)(b) — 9 cases
State v. Becklin, 182 P.3d 944 (Wash. 2008).
State v. Becklin, 163 Wash. 2d 519 (Wash. 2008).
State v. Bauer, 329 P.3d 67 (Wash. 2014). “The two-member majority also held that the facts of the case did not preclude the State from seeking to convict Bauer under the complicity statute, RCW 9A.08.020. Id. at 77 . The majority rejected Bauer’s vagueness argument.”
State v. Becklin, 133 Wash. App. 610 (Wash. Ct. App. 2006).
State v. Montejano, 147 Wash. App. 696 (Wash. Ct. App. 2008).
— Wash. Rev. Code § 9A.08.020(2)(c) — 26 cases
Waddington v. Sarausad, 555 U.S. 179 (2009). “” Wash. Rev. Code §§9A.08.020(1)–(3) (2008) (internal number ing omitted).”
State v. Davis, 682 P.2d 883 (Wash. 1984). “II It is clear from the plain meaning of the language in the accomplice liability statute, RCW 9A.08.020, that an accomplice to an armed robbery must know that a weapon is involved in order to be convicted as an accomplice to first degree robbery.”
Cesar Sarausad v. Carol Porter, Cesar Sarausad v. Carol Porter, 479 F.3d 671 (9th Cir. 2007).
State v. Roberts, 14 P.3d 713 (Wash. 2000). “The accomplice liability statute requires only a mens rea of knowledge, and an actus reus of soliciting, commanding, encouraging, or requesting the commission of the crime, or aiding or agreeing to aid in the planning of the crime.”
State v. Amezola, 741 P.2d 1024 (Wash. Ct. App. 1987).
— Wash. Rev. Code § 9A.08.020(3) — 117 cases
State v. Cronin, 14 P.3d 752 (Wash. 2000). “" It is their position that under our state's complicity statute, RCW 9A.08.020, a person is not culpable as an accomplice unless that person possesses general knowledge of the specific crime with which he or she is eventually charged.”
State v. Cronin, 142 Wash. 2d 568 (Wash. 2000).
State v. Elliott, 785 P.2d 440 (Wash. 1990).
McKenzy Alfred v. Merrick Garland, 64 F.4th 1025 (9th Cir. 2023).
State v. Williams, 150 P.3d 111 (Wash. Ct. App. 2007).
— Wash. Rev. Code § 9A.08.020(3)(a) — 111 cases
State v. Guloy, 705 P.2d 1182 (Wash. 1985).
State v. Hoffman, 804 P.2d 577 (Wash. 1991).
State v. Borrero, 58 P.3d 245 (Wash. 2002).
State v. Borrero, 147 Wash. 2d 353 (Wash. 2002).
State v. Roberts, 14 P.3d 713 (Wash. 2000). “The accomplice liability statute requires only a mens rea of knowledge, and an actus reus of soliciting, commanding, encouraging, or requesting the commission of the crime, or aiding or agreeing to aid in the planning of the crime.”
— Wash. Rev. Code § 9A.08.020(3)(a)(i) — 40 cases
United States v. Jose Valdivia-Flores, 876 F.3d 1201 (9th Cir. 2017). “Noticeably, no evidence in the record refers to Wash. Rev. Code § 9A.08.020 or suggests that Valdivia-Flores was convicted as an accomplice.”
State v. Truong, 168 Wash. App. 529 (Wash. Ct. App. 2012).
State v. Truong, 277 P.3d 74 (Wash. Ct. App. 2012).
State v. Walker, 341 P.3d 976 (Wash. 2015).
J. Marquez-Reyes v. Merrick Garland, 36 F.4th 1195 (9th Cir. 2022).
— Wash. Rev. Code § 9A.08.020(3)(a)(ii) — 35 cases
State v. Farnsworth, 374 P.3d 1152 (Wash. 2016).
State v. B.J.S., 140 Wash. App. 91 (Wash. Ct. App. 2007).
State Of Washington v. Nathaniel Shane Clark, 361 P.3d 168 (Wash. Ct. App. 2015).
State v. Farnsworth, 348 P.3d 759 (Wash. Ct. App. 2014).
State v. McDonald, 138 Wash. 2d 680 (Wash. 1999).
— Wash. Rev. Code § 9A.08.020(3)(b) — 6 cases
State v. Jackson, 976 P.2d 1229 (Wash. 1999). “The defendants respond that the instruction was erroneous because Washington’s accomplice liability statute, RCW 9A.08.020, does not impose liability on an individual for failing to perform a legal duty.”
State v. Stein, 27 P.3d 184 (Wash. 2001). “RCW 9A.08.020. In contrast, the conspiracy statute provides that: A person is guilty of criminal conspiracy when, with intent that conduct constituting a crime be performed, he or she agrees with one or more persons to engage in or cause the performance of such conduct, and any…”
State v. Stein, 144 Wash. 2d 236 (Wash. 2001). “RCW 9A.08.020. In contrast, the conspiracy statute provides that: A person is guilty of criminal conspiracy when, with intent that conduct constituting a crime be performed, he or she agrees with one or more persons to engage in or cause the performance of such conduct, and any…”
State v. Jackson, 976 P.2d 1229 (Wash. 1999).
State v. Montejano, 147 Wash. App. 696 (Wash. Ct. App. 2008).
— Wash. Rev. Code § 9A.08.020(3)(i) — 1 case
State of Washington v. Daniel Seth Arthur Holcomb (Wash. Ct. App. 2014).
— Wash. Rev. Code § 9A.08.020(4) — 2 cases
State v. Walker (Wash. 2015).
State v. Walker (Wash. 2015).
— Wash. Rev. Code § 9A.08.020(5) — 11 cases
City of Auburn v. Hedlund, 201 P.3d 315 (Wash. 2009). “At the close of the city of Auburn's case in chief, the trial court dismissed the DUI and reckless driving charges because a victim may not be charged as an accomplice under RCW 9A.08.020. We recognize that the legislature may have intended a more limited application of the…”
City of Auburn v. Hedlund, 165 Wash. 2d 645 (Wash. 2009). “At the close of the city of Auburn’s case in chief, the trial court dismissed the DUI and reckless driving charges because a victim may not be charged as an accomplice under RCW 9A.08.020. We recognize that the legislature may have intended a more limited application of the…”
State v. Wiebe, 377 P.3d 290 (Wash. Ct. App. 2016).
City of Auburn v. Hedlund, 155 P.3d 149 (Wash. Ct. App. 2007).
State v. Dudrey, 635 P.2d 750 (Wash. Ct. App. 1981).
— Wash. Rev. Code § 9A.08.020(5)(a) — 4 cases
State of Washington v. Christopher Floe (Wash. Ct. App. 2025).
State v. Gray (Wash. 2017).
State Of Washington, V Terrence C. Herndon (Wash. Ct. App. 2025).
State Of Washington, v, Lynn M. Cheroff (Wash. Ct. App. 2024).
— Wash. Rev. Code § 9A.08.020(5)(b) — 5 cases
State v. Wiebe, 377 P.3d 290 (Wash. Ct. App. 2016).
State v. Handley, 796 P.2d 1266 (Wash. 1990).
In re the Pers. Restraint of Kiet Hoang Le, 122 Wash. App. 816 (Wash. Ct. App. 2004).
In Re Le, 95 P.3d 1254 (Wash. Ct. App. 2004).
State Of Washington, V Jarrod A. Wiebe (Wash. Ct. App. 2016).
— Wash. Rev. Code § 9A.08.020(6) — 13 cases
State v. Harris, 725 P.2d 975 (Wash. 1986).
State v. Walker, 341 P.3d 976 (Wash. 2015).
State v. Mullin-Coston, 64 P.3d 40 (Wash. Ct. App. 2003).
State v. Mullin-Coston, 152 Wash. 2d 107 (Wash. 2004).
State v. Mullin-Coston, 95 P.3d 321 (Wash. 2004).
— Wash. Rev. Code § 9A.08.020(a)(i) — 1 case
Melvin Amaya v. Merrick Garland, 15 F.4th 976 (9th Cir. 2021).
— Wash. Rev. Code § 9A.08.020(a)(ii) — 1 case
State v. Mangan, 34 P.3d 254 (Wash. Ct. App. 2001).
— Wash. Rev. Code § 9A.08.020(c) — 1 case
State Of Washington, V Ronley Santer (Wash. Ct. App. 2018).
— Wash. Rev. Code § 9A.08.020(l) — 2 cases
Waddington v. Sarausad, 555 U.S. 179 (2009). “” Wash. Rev. Code §§9A.08.020(1)–(3) (2008) (internal number ing omitted).”
State v. Mullin-Coston, 152 Wash. 2d 107 (Wash. 2004).
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