California, United States of America
The following excerpt is from People v. Falaniko, 1 Cal.App.5th 1234, 205 Cal.Rptr.3d 623 (Cal. App. 2016):
sought to kill everyone in a particular area without having any primary target. (People v. McCloud, supra, 211 Cal.App.4th at p. 798, 149 Cal.Rptr.3d 902.) In addition, before a defendant may be convicted of attempted murder under a kill zone theory, the evidence must establish that all the victims were actually in the kill zone.
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