The theory of accomplice liability set forth at RCW 9A.08.020 permits the State to hold individuals accountable for the conduct of others. A person may be found guilty as an accomplice when, “[w]ith knowledge that it will promote or facilitate the commission of the crime,” the person “[s]olicits, commands, encourages, or requests such other person to commit it,” or “[a]ids or agrees to aid such other person in planning or committing it.” RCW 9A.08.020(3)(a)(i)-(ii). Essentially, the State “must prove the substantive crime was committed and the accused acted with knowledge that he or she was aiding in the commission of the offense.”
In the early hours of an August 2014 morning, three dead bodies of David Perez Saucedo Jr., Abigail Renteria Torres and Victoria Torres were found in a remote area of a Benton County farm. Forensic examiners opined that Mr. Saucedo and Abigail Torres had been shot at close range and died quickly. Mr. Saucedo had two gunshot wounds to his head. Abigail Torres had a single gunshot wound to her head and was discovered to have been pregnant with a full-term child. The condition of Victoria Torres' body was different. It appeared to examiners that Victoria Torres had been shot while trying to run away. Victoria Torres also had marks on her neck consistent with strangulation and a physical struggle. Law enforcement's investigation came to focus on Francisco Miranda, his father and his two brothers. Only Mr. Miranda was ultimately arrested. Mr. Miranda was charged with three counts of first degree murder with aggravating factors for there being more than one victim as to all three counts, RCW 10.95.020(10), and an additional aggravating factor based on the fact that one of the victims was pregnant at the time of her death, RCW 9.94A.535(3)(c). The jury found Mr. Miranda guilty of all three charges. Mr. Miranda argues the court should not have provided the jury with an accomplice liability instruction because it lacked evidentiary support.
Was there sufficient evidence to justify an accomplice liability instruction in this case?
The State presented sufficient evidence to justify an accomplice liability instruction. According to the trial testimony, Mr. Miranda and his brothers confronted Mr. Saucedo about burglarizing Mr. Miranda's apartment. Mr. Miranda and his family members then abducted Mr. Saucedo and his female companions and took them out to the farm. While it is unclear exactly who did what at the murder scene, the State's evidence shows Mr. Miranda played a significant role. Mr. Miranda procured a firearm before going out to the farm and he confessed to firing shots at the victims. Although Mr. Miranda's family members may have also facilitated the victims' deaths, the State's evidence showed Mr. Miranda was closely involved. The totality of the evidence provided a strong basis for the jury to find Mr. Miranda liable as either a principal or an accomplice to all three murders.