People v. Lee

Summary

The California Supreme Court interpreted Penal Code section 664(a) regarding life imprisonment for willful, deliberate, and premeditated attempted murder. The court held that the statute requires the attempted murder itself to have been willful, deliberate, and premeditated, but does not require an aider and abettor to have personally acted with those mental states, and affirmed the Court of Appeal's judgment.

Holdings

1. Section 664(a) requires only that the attempted murder was willful, deliberate, and premeditated; it does not require the defendant, including an aider and abettor, personally to have acted willfully, deliberately, and with premeditation.
2. The court did not decide the applicable prejudice standard because, under the correct interpretation of section 664(a), the trial court did not err by failing to instruct the jury that an aider and abettor must personally act willfully, deliberately, and with premeditation.

Questions Presented

1. Whether Penal Code section 664(a) requires an attempted murderer who is guilty as an aider and abettor personally to have acted willfully, deliberately, and with premeditation before the life-imprisonment penalty may be imposed.
2. Whether the court needed to decide the applicable prejudice standard for a trial court's failure to instruct the jury on personal willfulness, deliberation, and premeditation.

Disposition

affirmed