dissenting.
The majority reaffirms the position that complicitors can be held criminally liable for the unintentional acts of the principal. I would overrule our precedent, which the majority follows, because it is based upon the illogical proposition that one can be held legally accountable for intentionally assisting another who acted unintentionally, here recklessly, in the commission of a crime. Imposing liability for an unintentional crime committed by the principal eliminates the requirement that a complieitor must intentionally act with the same mental state as the principal, and creates the very real risk that a person will be convicted of a serious crime when the level of his participation in that crime was either remote or insignificant. The trial court in this ease recognized this incongruous result when it ruled that Gris-som, as a complieitor, could not commit the crime of complicity to reckless manslaughter. Because I would affirm the ruling of the trial court, I respectfully dissent.
Complicity is a legal theory which holds a defendant criminally liable for the same crime and punishment as the principal because the complieitor intentionally aided, abetted, or advised the principal who committed an offense. Palmer v. People, 964 P.2d 524, 528 (Colo.1998). The doctrine serves to punish individuals who have played a distinct role in the commission of an offense “without regard to whether they were or were not actually or constructively present at the time the crimes were committed.” 2 Wayne R. LaFave, et al., Substantive Criminal Law § 13.2, at 337 (2nd ed. 2003 & Supp.2005).
The General Assembly has defined a com-plieitor as one who acts with the intent to promote or facilitate an offense by aiding, abetting, or encouraging another to commit the criminal offense. Section 18-1-603, C.R.S. (2004), states:
A person is legally accountable as principal for the behavior of another constituting a criminal offense if, with the intent to promote or facilitate the commission of the offense, he or she aids, abets, advises, or encourages the other person in planning or committing the offense.
To prove that a defendant is complicit in the commission of a crime, the prosecution must prove a dual mental state before the complieitor may be held legally accountable for the offense of another. Bogdanov v. People, 941 P.2d 247, 250 (Colo.1997). The complieitor must have: (1) the culpable mental state required for the underlying crime committed by the principal; and (2) the intent to promote or facilitate the crime committed by the principal. Id. at 250-51 (citing 2 Wayne R. LaFave & Austin W. Scott, Jr., Criminal Law § 6.7 (1986)).
Criminal culpability in our system of justice arises out of the very basic theory that an individual is responsible for his own ac*1289tions.2 Thus, accomplice liability stems from the concept that a defendant took a personal and active role in the participation of an offense and not simply because he may have done something that resulted in another’s unlawful act. “It is not sufficient that the defendant intentionally engaged in acts which ultimately assisted or encouraged the principal. Rather, the complicitor must intend that his conduct have the effect of assisting or encouraging the principal in committing or planning the crime committed by the principal.” Bogdanov, 941 P.2d at 251.
Professor LaFave echoes this concern that a defendant may be held criminally liable as an accomplice despite a showing that the defendant’s act was not the legal cause of the crime committed by the principal. 2 La-Fave, Substantive Criminal Law § 13.2(e), at 354-55. He states that, where there is no requirement that the defendant’s act of assistance be part of the legal cause of the crime committed by the principal, liability “could easily be extended to all forms of assistance or encouragement to negligent or reckless conduct” without consideration to the defendant’s role in causing the crime. Id. at 355; see also Audrey Rogers, Accomplice Liability for Unintentional Crimes: Remaining Within the Constraints of Intent, 31 Loy. L.A. L.Rev. 1351, 1386, (1998) (stating that courts must not allow liability to rest on “merely foreseeable or knowing acts”).
In this ease, the majority holds that since the prosecution’s theory was that Grissom was a complicitor to the killing committed by the principal, Love, the jury should have been instructed that Grissom, as a complicitor, could be convicted of the lesser offense of reckless manslaughter.3 Applying the dual mental states of our complicity statute to the crime of reckless manslaughter, this means that a jury must find that Grissom had the identical mental state of the principal who committed reckless manslaughter and that Grissom had the intent to promote or assist Love when he committed reckless manslaughter.
The culpable mental state of reckless manslaughter requires the principal, the one who caused the death of the victim, to act with conscious disregard of a substantial and unjustifiable risk that a death will occur. § 18-1-501(8), C.R.S. (2004); § 18-3-104. Thus, to be a complicitor, Grissom would need to act with conscious disregard of a substantial and unjustifiable risk that death will occur and, at the same time, intend to assist Love to recklessly cause the death of the victim. One simply cannot intend a result that he does not intend.
Irrespective of the illogical theory of criminal liability that occurs when a defendant is convicted of intentionally aiding, abetting, or assisting a principal to commit a crime that the principal does not intend to commit, the majority holding imposes criminal liability on a person who neither intended nor committed the crime and may have only played an insignificant role in causing the crime.
By stating that the complicitor need not intend to commit the crime committed by the principal, the majority unjustifiably expands the defendant’s mens rea as required by the complicity statute and as interpreted in our case law. A complicitor must act with the “intent to promote or facilitate the commission of the offense” by the principal. § 18-1-603. And, the complicitor “must have the culpable mental state required for the underlying crime committed by the principal.” Bogdanov, 941 P.2d at 252. The majority, however, only requires that the complicitor intend to assist the principal in conduct that “grossly deviates from the standard of reasonable care.” Maj. op. at 1285. Thus, contrary to the express requirement found in statute and case law that the defendant in*1290tend to assist the principal to commit a specific criminal act, accomplice liability is expanded to include the intent to engage in any conduct that poses a substantial risk of harm to another.
To reach this result, the majority relies upon this court’s statement in People v. Wheeler, 772 P.2d 101, 104 (Colo.1989), which only required the eomplicitor to know that the principal “was about to engage in conduct that was a gross deviation from the standard of care that a reasonable person would exercise.” Maj. op. at 1283. This assertion disregards a fundamental tenet of criminal law that ties criminality to the defendant’s state of mind when the crime was committed. Under the majority’s holding, individuals who are only tangentially associated with the unintentional criminal conduct of the principal may be held criminally liable because of the principal’s negligent or reckless behavior.4 Such a holding is contrary to the fundamental principles of the criminal code which establish criminal culpability based upon the severity of a defendant’s conduct and the moral blameworthiness of his state of mind.
When a defendant, through his negligence or reckless conduct, causes the death of another, the General Assembly has provided a mechanism whereby such individuals can be tried and convicted for their acts of negligence or recklessness. See § 18-3-104 (Manslaughter); and § 18-3-105, C.R.S. (2004) (Criminally negligent homicide). The legal theory of complicity, however, does not allow the prosecution to impute to a defendant the reckless or negligent behavior of another which then resulted in an unintentional act simply because a defendant may have encouraged the principal to engage in behavior that creates a substantial or unjustifiable risk of harm. Therefore, I would overrule People v. Wheeler and apply the dual intent requirement for complicity as set forth in Bogdanov v. People.
A defendant should only be convicted under a theory of complicity when he intends to aide, abet, or assist the crime committed by the principal and not because he does an act, however insignificant it may be, that might cause or encourage the principal to commit an unintentional crime. The majority completely circumvents the dual intent requirement of complicity when it imposes criminal liability for a principal’s unintended crime. Hence, I respectfully dissent.
I am authorized to state that Justice KOURLIS joins in this dissent.
. See generally, Joshua Dressier, Reassessing the Theoretical Underpinnings of Accomplice Liability: New Solutions to an Old Problem, 37 Hastings L.J. 91, 103 (1985). Professor Dressier argues that accomplice liability ought to be limited to instances where there is a causal connection between the accomplice’s assistance and the ultimate crime committed by the principal. Where accomplice liability is not tied to issues of causation, unjust results of holding an accomplice strictly liable for the actions of the perpetrator can occur. Id. at 102-03.
. Section 18-3-104(l)(a), C.R.S. (2004), states that a person commits manslaughter if: "Such person recklessly causes the death of anther person ...”
. Rogers, Accomplice Liability for Unintentional Crimes, 31 Loy. L.A. L.Rev. at 1352-53 (providing examples of where accomplice may be liable for intending principal to engage in specific act, such as speeding, that results in unintentional death); Jacobs v. State, 184 So.2d 711, 717 (Fla. Dist.Ct.App.1966) (Carroll, J., dissenting) (giving example of onlookers at a drag race which results in the negligent death of another could be tried as complicitors simply because the race might not have occurred if they had not encouraged the racing).