In People v. Lee (2003) 31 Cal.4th 613, the Supreme Court examined the necessary showing for an aider and abettor to be found guilty of attempted willful, deliberate and premeditated murder under Penal Code section 664, subdivision (a). The court concluded the law required only that the murder attempted was willful, deliberate, and premeditated, not that the attempted murderer personally acted willfully and with deliberation and premeditation, even if he or she is guilty as an aider and abettor. (31 Cal.4th at p. 616.) The court noted that "the Legislature reasonably could have determined that an attempted murderer who is guilty as an aider and abettor, but who did not personally act with willfulness, deliberation, and premeditation, is sufficiently blameworthy to be punished with life imprisonment. ... Punishing such an attempted murderer with life imprisonment would not run counter to section 664(a)'s purpose of making the punishment proportionate to the crime." (Id. at p. 624.) The natural and probable consequences theory of liability was not present in Lee, but the court observed that "where the natural-and-probable-consequences doctrine does apply, an attempted murderer who is guilty as an aider and abettor may be less blameworthy. In light of such a possibility, it would not have been irrational for the Legislature to limit section 664(a) only to those attempted murderers who personally acted willfully and with deliberation and premeditation. But the Legislature has declined to do so." (Id. at pp. 624-625.)