PEOPLE v. ISABEL CELIS
A person may aid and abet a murder after fatal blow is struck as long as aiding and abetting occurs before victim dies. In trial of defendant who aided and abetted murder principal after he struck fatal blow to victim but before victim died, trial court did not err in failing to instruct jury sua sponte that murder is complete when fatal blow is struck even if victim lingers for substantial period of time. Trial court did not err in failing to instruct jury sua sponte on defense of mistake of fact where defendant never mentioned mistake of fact as defense theory. When court in response to jury's request instructed it that "directly and actively" committing crime meant "actually performing an act or acts which constitute a crime," trial court did not err in failing to also instruct them sua sponte on proximate cause where they never indicated desire to be informed on causation, and causation was not an issue in case. Trial court did not err in excluding evidence that defense witness expected to be sentenced to life imprisonment without possibility of parole where evidence would not have supported witness's credibility.
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