People v. Williams
California Courts of Appeal
142 Cal. Rptr. 704 (1977)
Williams (defendant), estranged from Charles Brooks, fought with him, was removed from his home, but returned with her sister Jo Ann to retrieve belongings over the objections of Brooks's brother-in-law, Tillman Washington. When Washington tried to stop her from taking anything, Williams drew a gun, and she and Washington struggled over it with the barrel near Williams's face; Williams repeatedly shouted at Jo Ann, who had also drawn a gun, to shoot Washington, and never tried to retreat or end the struggle. Jo Ann eventually shot and killed Washington. Both women were charged with murder; Jo Ann was acquitted on a defense-of-another theory, but Williams was convicted of second-degree murder and appealed, arguing her conviction couldn't stand given Jo Ann's acquittal.
Whether an individual may be held criminally liable as an accomplice to a crime even if the principal who actually committed the crime is eventually acquitted.