California, United States of America
The following excerpt is from People v. Meeks, E072894 (Cal. App. 2020):
The theory of transferred intent also does not apply to attempt crimes. "When a single act is charged as an attempt on the lives of two or more persons, the intent to kill element must be examined independently as to each alleged attempted murder victim; an intent to kill cannot be 'transferred' from one attempted murder victim to another under the transferred intent doctrine." (People v. Canizales (2019) 7 Cal.5th 591, 602.)
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