In People v. Ferlin (1928) 203 Cal. 587, it appeared the appellant had agreed to pay another person, Walter Skala, to burn a building. In setting the fire, Skala caused an explosion, was seriously burned, and eventually died from his injuries. ( Ferlin, supra, 203 Cal. at pp. 590-594.) Ferlin held that the appellant was not liable for murder under these circumstances. The court reasoned that Skala could not be held liable for murder for accidentally killing himself, and that his accidental death was not part of the common design of the conspiracy in which the appellant and Skala engaged. ( Id. at pp. 596-597.)