Opinion
S260063
03-25-2020
PEOPLE v. CARNEY (JAMES LEO)
C077558 Third Appellate District
Petition for review granted; issues limited
The petitions for review filed by Lonnie and Louis Mitchell are granted. The issues to be briefed and argued are limited to the following: Does the “substantial concurrent causation” theory of liability of People v. Sanchez (2001) 26 Cal.4th 834 permit a conviction for first degree murder if the defendants did not fire the shot that killed the victim? What impact, if any, do People v Chiu (2014) 59 Cal.4th 155 and Senate Bill No. 1437 (Stats. 2018, ch. 1015, § 1, subd. (f)) have on the rule of Sanchez?
The petition for review filed by James Carney is denied.
Votes: Cantil-Sakauye, C. J., Chin, Corrigan, Liu, Cuéllar, Kruger, and Groban, JJ.