In re Brigham

Opinion

MILLER, J.—

Petitioner was convicted in 1987 of first degree murder as an aider and abettor. In 2014, the California Supreme Court held that an aider and abettor may be convicted of first degree premeditated murder only under direct aiding and abetting principles, not under the natural and probable consequences doctrine. (People v. Chiu (2014) 59 Cal.4th 155, 158-159 [172 Cal.Rptr.3d 438, 325 P.3d 972] (Chiu).) Petitioner filed this writ, claiming the record does not establish beyond a reasonable doubt that the jury convicted him of first degree murder on a legally authorized ground. He…