Palmer v. People
1998 Colo. J. C.A.R. 4891, 964 P.2d 524, 1998 Colo. LEXIS 622 (1998)
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Rule of Law:
The crime of conspiracy requires the specific intent to cause the result of the target offense, which is legally and logically inconsistent with the crime of reckless manslaughter, where the resulting death is by definition unintentional.
Facts:
- Aaron Palmer fired gunshots at several victims.
Procedural Posture:
- Aaron Palmer was convicted in a Colorado district court (trial court) on multiple felony counts, including one count of conspiracy to commit reckless manslaughter.
- Palmer, as appellant, appealed his conviction to the Colorado Court of Appeals.
- The Court of Appeals, with the People as appellee, affirmed the conviction, holding that conspiracy to commit reckless manslaughter is a cognizable crime.
- Palmer petitioned the Colorado Supreme Court for a writ of certiorari on the issue of whether conspiracy to commit reckless manslaughter is a legally cognizable crime.
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Issue:
Does the crime of 'conspiracy to commit reckless manslaughter' exist as a legally cognizable offense under Colorado law?
Opinions:
Majority - Justice Bender
No. The crime of 'conspiracy to commit reckless manslaughter' is not a legally cognizable offense. Conspiracy is a specific intent crime that requires two distinct mental states: the specific intent to agree to commit a crime, and the specific intent to cause the specific result proscribed by that crime. In contrast, reckless manslaughter is defined by the culpable mental state of recklessness, which involves consciously disregarding a substantial risk that a death will occur—an unintentional result. It is legally and logically impossible to have the specific intent to bring about an unintended result; one cannot agree in advance to accomplish an unintended death. The court distinguished this from 'attempted reckless manslaughter,' which is a valid crime because attempt liability focuses on the defendant's conduct and adopts the mental state of the underlying offense (recklessness), rather than requiring a specific intent to cause the result. The court also distinguished this from complicity liability, as complicity is a legal theory, not a substantive offense, and the 'intent' required for complicity is given its plain meaning, not the strict statutory definition of specific intent.
Analysis:
This decision solidifies the strict mens rea requirements for the crime of conspiracy in Colorado, reinforcing that it is always a specific intent crime. It clarifies that the object of a conspiracy must be a result that can be intentionally achieved, thereby preventing the prosecution from charging logically inconsistent inchoate crimes. The ruling establishes a bright-line rule that distinguishes the specific intent requirement of conspiracy from the more flexible mental state requirements applicable to attempt and complicity, providing clarity for future cases involving inchoate liability for crimes of recklessness or negligence.
