California, United States of America
The following excerpt is from People v. Gonzales, 2d Crim. No. B264384 (Cal. App. 2018):
A person who is not the actual killer may be subject to life without the possibility of parole for a kidnapping special-circumstance murder only if he either (1) intends to kill ( 190.2, subd. (c)); or (1) acts with "reckless indifference to human life" and (2) "as a major participant," aids, abets, counsels, commands, induces, solicits, requests, or assists in the commission of the kidnapping ( 190.2, subd. (d); People v. Banks (2015) 61 Cal.4th 788, 797-798 (Banks)).
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