P. v. Abduh-Salam CA3
Defendants Raphael Abduh-Salam and Rena Abduh-Salam appeal from convictions of multiple crimes arising from three incidents of road-rage. Raphael contends (1) insufficient evidence supports his conviction of assault with a firearm; and (2) the trial court should reconsider a firearm enhancement imposed on him. Rena contends (1) insufficient evidence supports her conviction of making criminal threats; (2) the California causation standard applied to criminal threats is unconstitutional; and (3) the trial court erred by not instructing on the lesser included offense of attempted criminal threats.
Except to remand on the firearm enhancement, we affirm the judgment.
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