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Name: People v. Celis
Case #: B182346
Court: CA Court of Appeal
District 2 DCA
Division: 6
Opinion Date: 07/18/2006

For purposes of aider and abettor liability, a murder is complete when the victim dies, not when the fatal blow is rendered. In this murder trial, appellant argued the trial court erred in failing to instruct the jury that a murder is complete when the fatal blow is struck, even if the victim lingers for awhile before dying. Appellant complained that if the trial court had so instructed, she may have been found guilty of accessory after the fact rather than of aiding and abetting the murder. Canvassing a number of out-of-state cases, the Court of Appeal held that a murder ends with the death of the victim, and not before. Accordingly, the trial court had no duty to instruct as appellant urged.