People v. Prettyman
Supreme Court of California
926 P.2d 1013 (1996)
Relevant factsFree
Richard Prettyman (defendant) beat a homeless man, Gaylord Van Camp, to death with a pipe while Debra Bray (defendant) verbally encouraged him to "get" the victim. Both were charged with murder, with Bray's liability resting partly on the theory that the murder was a natural and probable consequence of some uncharged crime she aided. The trial court never identified what that uncharged target crime was. The jury convicted Bray, and she appealed.
IssueFree
Whether, in an aiding-and-abetting case relying on the natural-and-probable-consequences doctrine, the court must identify the uncharged target crime so the jury can determine whether the charged crime was a natural and probable result.