ARS Code 13-1003 Interpretation
A.R.S. 13-1003 provides, in part:
A. a person commits conspiracy if, with the intent to promote or aid the commission of an offense, such person agrees with one or more persons that at least one of them or another person will engage in conduct constituting the offense and one of the parties commits an overt act in furtherance of the offense. . . .
In State ex rel. Woods v. Cohen, 173 Ariz. 497, 844 P.2d 1147 (1992), Cohen had been charged with one count of conspiracy under A.R.S. 13-1003 and twelve counts of substantive offenses, such as theft and fraud, that had been committed by his co-conspirators.
After analyzing Arizona's conspiracy and accomplice statutes, the Cohen court concluded that the circumstances under which one could be held criminally liable for the conduct of another were exclusively defined by accomplice liability, and that "Pinkerton liability is not . . . the equivalent of accomplice liability." Id. at 500, 844 P.2d at 1150.