Does the natural and probable consequences doctrine apply to an aider and abettor in an attempted murder case?

We also reject Oregon's suggestion that the natural and probable consequences doctrine is inapplicable to attempted murder because the doctrine does not require proof of specific intent to kill. Although attempted murder requires express malice, i.e. specific intent to kill, not implied malice (People v. Collie (1981) 30 Cal.3d 43, 62), our courts have held that the natural and probable consequences doctrine in aiding and abetting situations can support a conviction of attempted murder (see People v. Prettyman (1996) 14 Cal.4th 248, 262-263). The specific intent necessary for conviction of an aider and abettor is not "the specific intent to kill, but the intent to 'encourage and bring about conduct that is criminal.'" (Olguin, supra, 31 Cal.App.4th at p. 1379 [rejecting implied malice arguments for aider and abettor liability].)

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

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