How have courts interpreted the principles of 'conspiracy' and 'reasonably foreseeable acts committed in furtherance of the common illegal objective'?

'It is true that in presenting its case the prosecution had recourse to the principles of conspiracy. However, this thesis, far from seeking to establish a basis of criminal liability separate and apart from that of aiding and abetting, was pursued for the purpose of demonstrating Durham's intimate involvement in the continuing criminal enterprise which culminated in the shooting of Officer Du Puis. (People v. Durham, 70 Cal.2d 171, 180, 74 Cal.Rptr. 262, 267, 449 P.2d 198, 203.)

Bohmer finds fault with language used by the court in an instruction to the jury

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'Reasonably foreseeable acts committed in furtherance of the common illegal objective' was said by the court to be the rule in defining the liability of a coconspirator in United States v. Manning, U.S.C.A.9th, 509 F.2d 1230, decided December 23, 1974.