Joe R. (defendant) was a minor who, along with his accomplice Michael Ryles, robbed a Taco Bell restaurant at gunpoint. After fleeing the restaurant, Joe and Ryles approached Wayne Anderson to rob him as Anderson was sitting on a bus bench. Ryles pointed his gun at Anderson’s head and forced him behind a building while demanding money, threatening to shoot him if he did not comply. Joe also threatened that Ryles would shoot Anderson, but never drew his own gun on Anderson. Anderson grabbed for Ryles’s gun, and Joe struck Anderson in the back of the head during the struggle. Anderson managed to get possession of Ryles’s gun, and as Joe fled, Anderson shot Ryles twice, killing him. Joe was charged and convicted of two counts of robbery and one count of murder and committed to the California Youth Authority. Joe appealed, alleging that the murder charge was not supported by the evidence.