Wyo. Stat. » Wyo. Stat. / Title 06 - Crimes and Offenses / Chapter 1 - GENERAL PROVISIONS / Article 2 - LIABILITY
Wyoming Statutes

Wyo. Stat. § 6-1-201 (2026)

Accessory before the fact.

✓ current as of May 2026
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(a) A person who knowingly aids or abets in the commission
of a felony, or who counsels, encourages, hires, commands or
procures a felony to be committed, is an accessory before the
fact.

     (b)    An accessory before the fact:

          (i) May be indicted, informed against, tried and
convicted as if he were a principal;

          (ii) May be indicted, informed against, tried and
convicted either before or after and whether or not the
principal offender is indicted, informed against, tried or
convicted; and

          (iii) Upon conviction, is subject to the same
punishment and penalties as are prescribed by law for the
punishment of the principal.
Notes of Decisions
Cited in 47 cases (6 in the last 5 years), 1982–2025 · leading case: Black v. State, 2002 WY 72 (Wyo. 2002).
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Black v. State, 2002 WY 72 (Wyo. 2002). · cites it 20× “[¶ 9] Wyo. Stat. Ann. § 6-1-201 (LexisNexis 2001) provides: (a) A person who knowingly aids and abets in the commission of a felony, or who counsels, encourages, hires, commands or procures a felony to be committed, is an accessory before the fact.”
Birr v. State, 744 P.2d 1117 (Wyo. 1987). · cites it 16× “Appellant Charles Edward Birr pleaded guilty to one count of accessory to felony murder, in violation of §§ 6-1-201 [1] and 6-2-101, W.S. 1977, [2] and one count of accessory to aggravated robbery, in violation of §§ 6-1-201 [3] and 6-2-401(c)(ii), W.”
Yellowbear v. State, 2008 WY 4 (Wyo. 2008). · cites it 10× “The State sought the death penalty, but the appellant was sentenced to life in prison without the possibility of parole. Blackburn entered into a plea agreement with the State whereby she pled guilty to an amended count of accessory before the fact to second-degree murder in…”
Gonzales v. Duenas-Alvarez, 549 U.S. 183 (2007). · cites it 2× “01 , 7.02(a) (West 2003); Utah Code Ann. § 76-2-202 (Lexis 2003); Vt.”
Haight v. State, 654 P.2d 1232 (Wyo. 1982). · cites it 9× “1977, and one count of attempted first degree sexual as *1234 sault in violation of §§ 6-1-201, W.S.1977, Cum.Supp.1981, and 6-4-302(a)(i), W.”
Duffy v. State, 789 P.2d 821 (Wyo. 1990). · cites it 6× “, and whether the proceedings were void and the sentence illegal?" In the initial proceedings, Duffy entered pleas of guilty to one count of aiding and abetting aggravated robbery in violation of §§ 6-1-201 and 6-2-401, W.S. 1977 (June 1983 Repl.”
Wyatt L. Bear Cloud, 2014 WY 113 (Wyo. 2014). · cites it 2× “Wyo. Stat. Ann. §§ 6-1-201 , 6-2-101(b). Miller dictates that sentencing courts must consider the individual cireumstances of each juvenile, including whether he is "the shooter [or] the accomplice," Miller, 567 U.”
Bouwkamp v. State, 833 P.2d 486 (Wyo. 1992). · cites it 4× “If the status of involvement is that of an accessory after the fact by definition, the conduct is separate and distinct.”
Tompkins v. State, 705 P.2d 836 (Wyo. 1985). · cites it 5× “Appellant Curtis Tompkins was convicted, by a jury, of aiding and abetting in the possession of a controlled substance, marijuana, with the intent to deliver, in violation of §§ 6-1-201(a) and (b)(ii) and 35-7-1031(a)(ii), W.”
Callen v. State, 2008 WY 107 (Wyo. 2008). · cites it 5× “2 The State ultimately charged Callen under Wyo. Stat. Ann. § 6-1-201 (LexisNexis 2007) with being an accessory before the fact for his involvement in the arson.”
Rawle v. State, 2007 WY 59 (Wyo. 2007). · cites it 5× “Wyo. Stat. Ann. § 6-1-201 (LexisNexis 2008) (emphasis added).”
Miller v. State, 755 P.2d 855 (Wyo. 1988). · cites it 4× “[2] Section 6-1-201(a), W.S. 1977 (June 1983 Replacement), provides in pertinent part: "A person who knowingly aids or abets in the commission of a felony, or who counsels, encourages, hires, commands or procures a felony to be committed, is an accessory before the fact.”
Show all 47 citing cases →
— Wyo. Stat. § 6-1-201(a) — 7 cases
Miller v. State, 755 P.2d 855 (Wyo. 1988). “[2] Section 6-1-201(a), W.S. 1977 (June 1983 Replacement), provides in pertinent part: "A person who knowingly aids or abets in the commission of a felony, or who counsels, encourages, hires, commands or procures a felony to be committed, is an accessory before the fact.”
Burke v. State, 746 P.2d 852 (Wyo. 1987).
Duffy v. State, 837 P.2d 1047 (Wyo. 1992).
Tompkins v. State, 705 P.2d 836 (Wyo. 1985). “Appellant Curtis Tompkins was convicted, by a jury, of aiding and abetting in the possession of a controlled substance, marijuana, with the intent to deliver, in violation of §§ 6-1-201(a) and (b)(ii) and 35-7-1031(a)(ii), W.”
Callen v. State, 2008 WY 107 (Wyo. 2008). “2 The State ultimately charged Callen under Wyo. Stat. Ann. § 6-1-201 (LexisNexis 2007) with being an accessory before the fact for his involvement in the arson.”
— Wyo. Stat. § 6-1-201(a)(b)(i) — 1 case
Duffy v. State, 730 P.2d 754 (Wyo. 1986).
— Wyo. Stat. § 6-1-201(a)(i) — 2 cases
Osborn v. State, 672 P.2d 777 (Wyo. 1983).
Capwell v. State, 686 P.2d 1148 (Wyo. 1984).
— Wyo. Stat. § 6-1-201(b) — 1 case
Harvey v. State, 774 P.2d 87 (Wyo. 1989).
— Wyo. Stat. § 6-1-201(b)(ii) — 2 cases
Tompkins v. State, 705 P.2d 836 (Wyo. 1985). “Appellant Curtis Tompkins was convicted, by a jury, of aiding and abetting in the possession of a controlled substance, marijuana, with the intent to deliver, in violation of §§ 6-1-201(a) and (b)(ii) and 35-7-1031(a)(ii), W.”
Michael Antonio Patterson v. The State of Wyoming, 2013 WY 153 (Wyo. 2013).
— Wyo. Stat. § 6-1-201(b)(iii) — 1 case
Christopher Robert Hicks v. The State of Wyoming, 2025 WY 113 (Wyo. 2025).
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