California, United States of America
The following excerpt is from People v. Brown, 226 Cal.App.3d 1361, 277 Cal.Rptr. 309 (Cal. App. 1991):
Since both theories of coconspirator liability for the robbery are sustainable on this record and because it is impossible to tell under which theory the jury reached its verdict, the robbery conviction is suspect and must be reversed. (People v. Green (1980) 27 Cal.3d 1, 69, 71, 164 Cal.Rptr. 1, 609 P.2d 468.)
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