In People v. Taylor (1974) 12 Cal.3d 686, three men planned a liquor store robbery. ( Id. at p. 691.) Two men entered a liquor store while the third remained outside in the getaway car. (Ibid.) A gun battle ensued and one of the robbers was killed. The other confederate who entered the liquor store was acquitted of murder, but in a separate trial, the man in the getaway car was convicted of first degree murder. (Ibid.) The court reversed the conviction, holding collateral estoppel applicable "where an accused's guilt is predicated on his vicarious liability for the acts of a previously acquitted confederate." ( Id. at p. 698.) The court stressed that it was limiting its holding "to the particular circumstances of the instant case.. . . ." (Ibid.) It expressly declined to "reach the question of whether the doctrine of collateral estoppel should be applied to bar prosecution of a person who directed, instigated or participated in a crime for which the perpetrators were acquitted." ( Id. at p. 697, fn. 14.)