Does the natural and probable consequence of a gang-related assault result in murder or attempted murder?

As discussed in People v. Medina (2009) 46 Cal.4th 913, it is quite foreseeable that a gang-related assault will result in murder or attempted murder, even if the aider and abettor does not know the principal is armed. "'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 latter question is not whether the aider and abettor actually foresaw the additional crime, but whether, judged objectively, it was reasonably foreseeable. [Citations.]'" (Id. at p. 920.)

Similar principles govern the vicarious liability of coconspirators.

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Appellant cites no published case holding that the natural and probable consequences doctrine is analogous to or a form of implied malice. There are, however, "a number of California cases which hold murder or attempted murder can be a natural and probable consequence of [aiding and abetting a] robbery. [Citations.]" (People v. Cummins (2005) 127 Cal.App.4th 667, 677.) We similarly conclude that the jury was correctly instructed that appellant could be found guilty of attempted murder under a conspiracy theory of liability if it found the natural and probable consequence of the uncharged conspiracy to commit robbery or assault was the attempted murder of a police officer.