California, United States of America
The following excerpt is from People v. Smith, 180 Cal.Rptr.3d 100, 337 P.3d 1159, 60 Cal.4th 603 (Cal. 2014):
As we have explained, that finding, if combined with the other findings beyond a reasonable doubt necessary to convictthat whoever committed the murder was a principal in the target crimes, that defendant aided and abetted the target crimes, and that the murders were a natural and probable consequence of the target crimeswould mean each juror was convinced beyond a reasonable doubt that defendant was guilty of murder. No additional unanimity is required. The jury certainly had to find that someone committed murder. But the jury simply did not have to find exactly who that person was. (People v. Culuko (2000) 78 Cal.App.4th 307, 323, 92 Cal.Rptr.2d 789 [applying these principles in a case involving the natural and probable consequence doctrine].)
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