Echols v. State

In Echols v. State, 818 P.2d 691 (Alaska App. 1991), the Court reversed Echols's first-degree assault conviction based on the defendant's accomplice liability for her spouse's assault of their daughter. The superior court had ruled that, under Alaska's accomplice liability statute, Echols could be convicted for acting recklessly regarding the results of her husband's conduct. The Court ruled that, to be liable for the acts of her husband, Echols must have intended that the result of the underlying assault statute occur -- even though the underlying assault statute requires proof of only a lesser culpable mental state.