California, United States of America
The following excerpt is from People v. Bruno-Martinez, No. C060660 (Cal. App. 3/30/2010), No. C060660. (Cal. App. 2010):
Nevertheless, the court recognized that while transferred intent is not appropriate for attempted murder, a defendant who shoots into a group of people within a "kill zone" may be held liable for attempting to kill all of them on a concurrent intent theory. (People v. Bland, supra, 28 Cal.4th at p. 329.) "`The intent is concurrent . . . when the nature and scope of the attack, while directed at a primary victim, are such that we can conclude the perpetrator intended to ensure harm to the primary victim by harming everyone in that victim's vicinity." (Ibid.)
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