Can a defendant plead guilty to premeditated murder in order to prove that another defendant committed murder rather than manslaughter?

^8. The converse of defendant's argument is helpful to understand its fallacy. A prosecutor would not be able to introduce evidence that Defendant A pled guilty to premeditated murder in order to prove that Defendant B had also committed murder rather than manslaughter. (People v. Cummings (1993) 4 Cal.4th 1233, 1322 [one defendant's guilty plea is inadmissible to prove that another defendant participated in the crime]; see United States v. Halbert (1981) 640 F.2d 1000, 1004 ["As a principle of general acceptance, guilty plea or conviction of a codefendant may not be offered by the government and received over objection as substantive evidence of the guilt of those on trial."].) Doctrinally, we see no difference to introduction of such evidence by the defense.

^9. All future undesignated statutory references are to the Penal Code.

^10. Former section 12280, subdivision (b) was repealed and replaced by section 30605, subdivision (a), which reads: "Any person who, within this state, possesses any assault weapon, except as provided in this chapter, shall be punished by imprisonment in a county jail for a period not exceeding one year, or by imprisonment pursuant to subdivision (h) of Section 1170." Section 30605 became operative on January 1, 2012.

^11. Black, supra, was later overruled on other grounds by Cunningham v. California (2007) 549 U.S. 270.