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First Degree Murder–Substantial Concurrent Causation Theory (Sanchez) and Impact of Chiu and SB 1437

Case Name: People v. Carney (Dec. 10, 2019) [nonpub. opn.], review granted 3/25/2020
Case #: S260063/C077558

(1) 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? (2) 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?

On 10/13/2021, the parties were directed to serve and file letter briefs on or before November 4, 2021 addressing the significance, if any, of Senate Bill No. 775 (Stats. 2021, ch. 551) to the issues presented in this case.