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P. v. Clayton CA4/12
Senate Bill No. 1437 amended the mens rea requirements for murder and “restricted the circumstances under which a person can be liable for murder under the felony-murder rule or the natural and probable consequences doctrine. (Stats. 2018, ch. 1015.)” (People v. Lamoureux (2019) 42 Cal.App.5th 241, 246 (Lamoureux).) As a result, the mens rea required for a murder conviction, malice aforethought, “shall not be imputed to a person based solely on his or her participation in a crime.” (Stats. 2018, ch. 1015, § 2 [amending Pen. Code, § 188].)

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