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Keywords

defendantliabilitystatute

defendantliabilitystatuteappeal

Related Cases

Butler v. People, 450 P.3d 714, 2019 CO 87

Facts

In early 2013, Clayton Schaner was investigated for using his computer repair store, Just Computers, to buy and resell stolen goods. Caleb Charles Butler, the store's assistant manager, was found to have facilitated Schaner's operations by transferring money and assisting in transactions involving stolen items. Both were arrested, and Butler was convicted of two counts of money laundering related to specific transactions involving stolen goods.

In early 2013, an undercover officer sold Clayton Schaner a series of ostensibly stolen goods as part of an investigation into whether Schaner was using his computer repair store, Just Computers, as a front to buy and resell stolen items on e-commerce websites.

Issue

Whether a defendant who was not physically present during the commission of the charged crimes, did not take any specific action to facilitate or promote those particular crimes, and had no apparent knowledge that the principal intended to commit the crimes in question, can be held criminally liable as a complicitor.

Whether a defendant who (1) was not physically present during the commission of the charged crimes; (2) did not take any specific action to facilitate or promote those particular crimes; and (3) had no apparent knowledge that the principal intended to commit the crimes in question, can be held criminally liable as a complicitor under the test set forth in People v. Childress, 2015 CO 65M, 363 P.3d 155.

Rule

A person is legally accountable as principal for the behavior of another constituting a criminal offense if, with the intent to promote or facilitate the commission of the offense, he or she aids, abets, advises, or encourages the other person in planning or committing the offense.

Colorado's complicitor liability statute provides that a person is 'legally accountable as principal for the behavior of another constituting a criminal offense if, with the intent to promote or facilitate the commission of the offense, he or she aids, abets, advises, or encourages the other person in planning or committing the offense.'

Analysis

The court analyzed whether Butler's actions met the criteria for complicitor liability under Colorado's money laundering statute. It concluded that while Butler's overall participation in Schaner's operation was not enough to establish liability for the specific acts charged, there was sufficient evidence that he aided and abetted Schaner in the specific money laundering transactions involving the razor blades and the drill.

We therefore conclude that the court of appeals was incorrect insofar as it suggested that the prosecution need only prove Butler's participation in the operation rather than in the specific acts of money laundering charged.

Conclusion

The court affirmed Butler's convictions, concluding that there was sufficient evidence to support the jury's finding of complicity in the specific acts of money laundering.

We therefore uphold Butler's convictions.

Who won?

The People (prosecution) prevailed because the court found sufficient evidence to support Butler's complicity in the specific money laundering transactions.

The court concluded that there was sufficient evidence in the record to support Butler's convictions.

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