The CSC has granted review in several cases to consider whether to convict an aider and abettor of attempted willful, deliberate and premeditated murder under the natural and probable consequences doctrine, must a premeditated attempt to murder have been a natural and probable consequence of the target offense? In other words, should People v. Favor (2012) 54 Cal.4th 868 be reconsidered in light of Alleyne v. United States (2013) ___ U.S. ___ [113 S.Ct. 2151] and People v. Chiu (2014) 59 Cal.4th 155?
See People v. Mateo (Feb. 10, 2015, B258333) [nonpub. opn.], review granted 5/11/2016 (S232674); see also People v. Gutierrez (Mar. 3, 2016, B250333) [nonpub. opn.], review granted 5/25/2016 (S233295); People v. Morales (Feb. 17, 2016, B253249) [nonpub. opn.], review granted 5/25/2016 (S233255).) Briefing in Gutierrez and Morales was deferred pending decision in Mateo. [NF]