People v. Scott
Supreme Court of California
927 P.2d 288 (1996)
After a falling-out and physical altercation between Calvin Hughes and Elaine Scott, Scott's adult sons Damien Scott and Derrick Brown (defendants) forced Hughes from the apartment. Days later they followed Hughes to a park and sprayed it with automatic gunfire meaning to kill him; a bystander died instead and others were wounded. The defendants were convicted of second-degree murder of the bystander and attempted murder of Hughes and his friend, over their objection that transferred intent could not apply once they were also charged with attempted murder of the intended victim.
Whether the doctrine of transferred intent may assign murder liability for an unintended victim's death even when the defendant is separately prosecuted for the attempted murder of the intended victim.