Can an aider and abettor be held criminally responsible for any other crime that is a natural and probable consequence of the target crime?

Previously, under the natural and probable consequences doctrine, an aider and abettor could "'be held criminally responsible . . . not only for the crime he or she intended to aid and abet (the target crime), but also for any other crime [nontarget crime] that is the "natural and probable consequence" of the target crime.' [Citation.] To find an aider and abettor guilty of a nontarget crime under the natural and probable consequences theory, the jury must find that the defendant aided and abetted the target crime, that a coparticipant in the target crime also committed a nontarget crime, and that this nontarget crime was a natural and probable consequence of the target crime the defendant aided and abetted. [Citation.]" (People v. Hardy (2018) 5 Cal.5th 56, 92.)

The natural and probable consequences doctrine did not apply to first degree murder (People v. Chiu, supra, 59 Cal.4th at pp. 166-167); an aider and abettor could not be guilty of first degree murder unless he or she personally deliberated, premeditated, and intended to kill. (Id. at p. 166.) However, it did apply to second degree murder. (Id. at pp. 165-166.)

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