California, United States of America
The following excerpt is from People v. Bengoa, G048244 (Cal. App. 2014):
The "specified circumstances" referred to - under which an aider and abettor of one crime can be found guilty of other crimes - were then revealed to be those comprising the natural and probable consequences doctrine and the uncharged conspiracy. Thus, those two theories were not proposed as separate and distinct justifications for holding defendant responsible for the charged robberies; instead, they were posited only as support for finding defendant guilty of the robberies as an aider and abettor. The court' s instructions told the jury that defendant could be found guilty of robbery under the natural and probable consequences doctrine if the prosecution established (1) defendant was guilty of theft, (2) during the commission of that theft, a coparticipant committed the robbery, and (3) a reasonable person in defendant's position would have known that the robbery was a natural and probable consequence of the theft. This was proper. (People v. Medina (2009) 46 Cal.4th 913, 920 ["'[a] person who knowingly aids and abets criminal conduct is guilty of not only the intended crime [target offense] but also of any other crime the perpetrator actually commits [nontarget offense] that is a natural and probable consequence of the intended crime'"].) The instructions also told the jury that if it found defendant had participated in a conspiracy to commit
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