California, United States of America
The following excerpt is from People v. Bengoa, G048244 (Cal. App. 2014):
That use of an uncharged conspiracy - to establish defendant's complicity in an uncharged "target crime" which in turn was found to have precipitated the charged crime as a natural and probable consequence - is well established as a basis for extending a defendant's liability as an aider and abettor, to the charged crime. (People v. Prieto, supra, 30 Cal.4th at pp. 249-250.) Consequently, we conclude there was no error in these instructions.
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