People v. Prettyman
California Supreme Court
14 Cal. 4th 248, 58 Cal. Rptr. 2d 827, 926 P.2d 1013 (1996)
In July 1992, Richard Prettyman (defendant) beat Gaylord Van Camp, a homeless man, with a pipe, killing him. At the time, witnesses saw and heard Debra Bray (defendant) verbally encourage Prettyman to “get” Van Camp. The State of California (plaintiff) charged both Prettyman and Bray with murder, contending that Bray was guilty of the crime as an accomplice because she encouraged Prettyman’s conduct. The trial court instructed the jury that Bray was guilty of murder if it was determined either that Bray directly aided and abetted the murder, or that Van Camp’s murder was a natural and probable consequence of any uncharged offenses that Bray aided and abetted. The court did not identify or describe any uncharged target offenses that Bray may have aided or abetted. The jury convicted Bray, and she appealed, contending that the court erred in not instructing the jury on specific uncharged target crimes Bray may have encouraged.
Rule of Law
Holding and Reasoning (Kennard, J.)
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