Is there insufficient evidence to support a claim that Simons acted as an aider and abettor or a perpetrator or perpetrator under the Civil Rights Act?

^4. Even if the error deprived Simons of any federal constitutional right, the error was also harmless beyond a reasonable doubt under the harmless error standard of Chapman v. California (1967) 386 U.S. 18, 24.

^5. Simons does not appear to argue that there is insufficient evidence to establish that he acted as either a perpetrator or an aider and abettor if there is, in fact, substantial evidence that one of the three participants discharged a firearm in the manner required under the statute.

^6. People v. Superior Court (Romero) (1996) 13 Cal.4th 497.