P. v. Adams CA2/4
A jury convicted appellant Leo Lloyd Adams of two counts of first degree murder and three counts of attempted murder as an aider and abettor, with gang and firearm enhancements. In an opinion filed in June 2015, we affirmed the judgment. Thereafter, the California Supreme Court decided People v. Chiu (2014) 59 Cal.4th 155, 167 (Chiu), which held that a defendant may not be convicted of first degree murder on a theory of natural and probable consequences. In July 2015, we modified our initial opinion in light of Chiu, finding that any error caused by instructing the jury on the natural and probable consequences doctrine was harmless beyond a reasonable doubt.
The California Supreme Court granted review, and later remanded the case to this court with directions to vacate our previous decision, and to reconsider the case in light of In re Martinez (2017) 3 Cal.5th 1216 (Martinez).
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