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People v. Prettyman | 926 P.2d 1013 (1996)
When an accomplice encourages a perpetrator to commit one crime and the perpetrator commits an additional, more serious crime, the accomplice is liable for the more serious crime if it was a foreseeable result of the crime that the accomplice originally contemplated. People versus Prettyman explains this doctrine and the jury instructions that must accompany it.
A witness overheard Debra Bray repeatedly tell Richard Prettyman to get Gaylord Van Camp shortly before Prettyman beat Van Camp to death with a steel pipe.
The People of California charged Prettyman and Bray with murder. The prosecution argued that Bray was guilty because she intentionally encouraged Prettyman to murder Van Camp.
The judge instructed the jury it could convict Bray of murder if it found that she aided and abetted the murder, or if the murder was a natural and probable consequence of an uncharged crime that she aided and abetted. The judge didn’t name or describe any such uncharged crime.
The jury convicted Prettyman and Bray. The court of appeal affirmed. Bray appealed to the California Supreme Court, arguing that the jury instructions were erroneous.
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