Criminal Law, Pages 557–561

People v. Prettyman

Supreme Court of California, 1996

Facts:

Defendant Bray and defendant Prettyman, who were both homeless, had been arguing at a church after the service. Van Camp got a church worker to intervene, and he had Van Camp take Prettyman away until he calmed down. Before they left, Bray gave Van Camp her wallet for safekeeping so Prettyman could not steal it from her. That night, Van Camp was sleeping in the church courtyard when Bray encouraged Prettyman to "get" him. Prettyman then beat Van Camp to death with a steel pipe to get Bray's wallet back to her.

Procedural History:

Both defendants were convicted of first degree murder.

Issue:

Did Bray have the knowledge required to be an accomplice to the murder?

Reasoning:

A defendant who assisted or encouraged another in the commission of assault with a deadly weapon that ends up causing someone's death could be convicted of murder under the natural and probable consequences doctrine. However, the targeted crime should be identified to facilitate the jury's task of determining whether the charged crime was a natural and probable consequence thereof. The trial court did not do this here.

If Bray only encouraged Prettyman to assault Van Camp but did not have reason to know he would use a steel pipe to do so, she could not be convicted of murder. The jury does not have to agree on what the targeted offense was, but it must believe that the charged offense was a natural and probable consequence thereof, not just some unspecified "nefarious" conduct.

Holding:

Bray could have had the knowledge required to be an accomplice if she knew defendant intended to use the steel pipe.


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