California, United States of America
The following excerpt is from People v. Salcido, E072629 (Cal. App. 2020):
In 2018, petitioner filed a habeas petition, seeking relief based on People v. Chiu (2014) 59 Cal.4th 155, which had held that an aider and abettor cannot be convicted of premeditated first degree murder under the natural and probable consequences doctrine; rather, an aider and abettor must personally premeditate, deliberate, and intend to kill.
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