Is there any case law in which a defendant was convicted under both a direct aiding and abetting theory and a natural and probable consequences theory?
California, United States of America
The following excerpt is from People v. Cummings, B299490 (Cal. App. 2021):
4. Defendant points to language in this court's brief order denying his petition for writ of habeas corpus that states he was convicted under a direct aiding and abetting theory as well as a natural and probable consequences theory. The language of the summary denial order, which resolved a different issue presented, is not determinative here. (Kowis v. Howard (1992) 3 Cal.4th 888, 894-896.)
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