Can a defendant be convicted as both a principal and an accessory after the fact?

California, United States of America

The following excerpt is from People v. Perkins, B302370 (Cal. App. 2021):

A defendant may be convicted as both a principal and an accessory where the convictions depend on entirely different conduct. (People v. Riley (1993) 20 Cal.App.4th 1808, 1814-1815 [affirming convictions of murder and accessory to murder].) Defendant Perkins contends his conviction for accessory after the fact cannot stand because it was based, in part, on the same conduct for which he was convicted of murder.

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