California, United States of America
The following excerpt is from People v. Prado, B224378 (Cal. App. 2012):
Prado contends that the trial court's instructions on the natural and probable consequences doctrine permitted the jury to convict Prado of murder as a consequence of aiding and abetting an assault, thereby violating the "merger" doctrine first applied in California by People v. Ireland (1969) 70 Cal.2d 522 (Ireland).
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