Bogdanov v. People

The defendant, Branko Bogdanov (Bogda-nov), was convicted under a complicity theory of second degree burglary of a warehouse1 and theft;2 and of criminal conspiracy to commit theft.3 On appeal, Bogdanov argued, among other things, that the standard jury instruction on complicity violated his right to due process of law. The court of appeals disagreed, relying on People v. Close, 867 P.2d 82 (Colo.App.1993). See People v. Bogdanov, No. 92CA1623, slip op. at 6-8 (Colo.App. Dec. 14, 1995) (not selected for official publication). We granted certiorari to determine whether the pattern complicity…