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In re Thompson CA2/7
In 1990, petitioner Sekou Kwane Thompson was convicted of first degree murder (Pen. Code, §§ 187, 189), exploding or igniting a destructive device causing death (former § 12310, subd. (a)), and exploding or igniting a destructive device causing bodily injury (former § 12309). He was sentenced to state prison for a term of life without the possibility of parole. In 2014, the California Supreme Court held that “an aider and abettor may not be convicted of first degree premeditated murder under the natural and probable consequences doctrine,” and that “his or her liability for that crime must be based on direct aiding principles.” (People v. Chiu (2014) 59 Cal.4th 155, 158-159 (Chiu).)

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