How have courts interpreted the doctrine of natural and probable consequences in a murder case?

abets only an intended assault, but a murder results, that person may be guilty of that murder, even if unintended, if it is a natural and probable consequence of the intended assault." (People v. McCoy (2001) 25 Cal.4th 1111, 1117 (McCoy), citation omitted.) Accordingly, pursuant to CALCRIM No. 403, the trial court instructed the jury on the natural and probable consequences doctrine as follows:

Appellant contends the trial court committed reversible error because this instruction failed to inform the jury that it had to find first degree premeditated murder, not simply murder, was the natural and probable consequence of the target crimes. Appellant did not object to the instruction on this basis at trial. Nevertheless, we consider appellant's argument on the merits because a defendant's contention that an instruction misstated the law or violated the defendant's right to due process need not be preserved by objection. (People v. Smithey (1999) 20 Cal.4th 936, 976, fn. 7; 1259.) After considering the merits, we are not persuaded.