In re Sandoval CA4/3
Jonathan Aguilar Sandoval challenges the trial court’s denial of his habeas petition based on the Supreme Court’s holding in People v. Chiu (2014) 59 Cal.4th 155 (Chiu) that the natural and probable consequences doctrine does not extend to first degree premeditated murder. As we explain, the error identified in Chiu did not occur here because the trial court’s instructions only allowed the jury to find Sandoval guilty of first degree premeditated murder based on his premeditation and deliberation rather than an accomplice’s. We therefore deny the writ petition.
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