Marquiz v. People
Colorado Supreme Court
726 P.2d 1105 (1986)
Steven Richard Marquiz, Rudy Gallegos, and Antonio Laroza (defendants) induced 17-year-old Debra Terhorst to accompany them to Lookout Mountain, where they stabbed and killed her; all three were charged with first-degree murder and conspiracy to commit first-degree murder, but their cases were severed for separate trials. Gallegos was found guilty of murder but not guilty of conspiracy; Laroza was found not guilty on both counts; Marquiz was found guilty on both counts and appealed, arguing his conspiracy conviction couldn't stand given that neither of his alleged co-conspirators was found guilty of conspiracy in their own separate trials.
Whether the Rule of Consistency applies when co-conspirators are tried in separate proceedings.