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The first questions is "is "implied" enough?" One of the criteria for CM status is "We know they did it. We saw them do it." "Implied responsibility" doesn't fulfill that criteria.
...if you don’t love you’re dead, and if you do, they’ll kill you for it.
And if we know they are nonetheless responsible for it?
CM status isn't transitive; a CM can be employed, controlled and manipulated by a regular villain without changing the employer's moral status beyond showing that they're willing to use a CM.
However… if CM level stuff was done by people who, narrative-wise, were nothing more than extensions of the employer's will, such as Faceless Goons or mind control victims, while having the employer watch in approval, or manical laughter or something like that
So, I guess my answer is 'yes, but only if you have a sufficiently irrelevant proxy.'
... so, as in, if Ganondorf was supposedly behind Zant's evil deeds in Twilight Princess, that would make either Ganondorf a CM or Zant a non-CM?
Lost in Space
Was Zant mind controlled or doing things his "personal" way? Was Ganon directly responsible for having him do the precise things he did? The example would be the difference between saying, "Kill him and his family," and, "Tie him to a chair. Cut off his legs. Rape his wife and kids. Tie knives to their hands and have them stab each other to death in front of him." Etc.
"It's Occam's Shuriken! If the answer is elusive, never rule out ninjas!"
I do not know Twilight Princess well enough to answer these questions. Perhaps someone more familiar with that game could come in and answer it...
Well as might step in here, then.
Zant appears to be the Big Bad for most of the game until he gets Hijacked by Ganon. So, he was acting under Ganondorf's orders, but not mind controlled or anything.
For purposes of CM status, the fact that Zant was working under Ganondorf is largely irrelevant. Zant is responsible for his own actions, in this context.
When it was recommended that Ganondorf from The Legend Of Zelda be removed from the video game Complete Monster list, I do not recall people making a similar recommendation for Zant, even though Ganondorf is supposedly implied to be "behind Zant's atrocities." Wouldn't that make them Ganondorf's atrocities by extension?
I guess the key question here, and in turn, one that applies to other examples, is whether or not a character can be a CM based on them being responsible for evil deeds engaged in by other characters.