In People v. Taylor, 527 P.2d 622 (Cal.1974), Taylor, Daniels, and Smith planned to rob a liquor store owned by Jack and Linda West. Taylor remained in a vehicle while Daniels and Smith entered the store and robbed the Wests of money at gunpoint. During the altercation, a gun battle broke out during which the Wests shot and killed Smith. Taylor was charged with Smith’s murder on a theory of vicarious liability. Before Taylor’s trial, Daniels was tried for, but acquitted of Smith’s murder. In light of that verdict, the Taylor court held that the principle of collateral estoppel prohibited Taylor from being tried for the same murder. In People v. Sparks, a case with very similar facts, the California Supreme Court instructed the prosecution and the superior court to brief the question of whether Taylor should be overruled.