People v. Carney

Summary

The court held that defendants who participated in a public gun battle could be convicted of first degree murder even though neither fired the bullet that killed the bystander. Their life-threatening conduct could constitute a substantial concurrent and proximate cause of the death, provided it was a substantial factor and the death was a foreseeable consequence. The court also held that the rules governing imputed malice and accomplice liability did not alter this causation analysis.