Riley v. State
Court of Appeals of Alaska
60 P.3d 204 (2002)
Richard Riley and Edward Portalla fired guns into a crowd at a bonfire, seriously wounding two people; the State could not determine whose shots caused the injuries. Both were charged with two counts of first-degree assault, which requires recklessly causing serious physical injury with a dangerous weapon. The jury was told it could convict Riley either as the principal shooter or as an accomplice who aided and abetted Portalla, and it convicted him as an accomplice on both counts. Riley appealed, arguing the accomplice-liability instructions should have required proof he specifically intended for Portalla to cause serious injury.
Whether a defendant can be convicted as an accomplice to a result crime like first-degree assault based only on sharing the principal's reckless mental state toward the result, rather than intending the result itself.