State v. BARANOVICH, 249 P.3d 1284

Defendant Baranovich was convicted of second-degree assault (ORS 163.175) for an ambush where her brother struck the victim with a rock.
The victim and defendant were previously friends; the friendship deteriorated, leading to threats by defendant.
During the attack, defendant hid in bushes; her brother assaulted the victim with a rock and they fled in Mashtalyar's car.
Mashtalyar drove the car; police later found rock, pepper spray, ski mask, and a bat in the car related to the plan.
Defendant and Mashtalyar were charged with two counts: second-degree assault by means of a rock and third-degree assault; defendant was convicted on the second-degree theory via accomplice liability.
Defendant argued she did not intend to aid a second-degree assault with a dangerous weapon and relied on a natural-and-probable-consequences theory.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there sufficient evidence of intent to aid a dangerous-weapon assault?	State argues defendant intended to aid a second-degree assault with a weapon.	Baranovich contends she only intended a simple assault with a fist.	Yes; sufficient circumstantial evidence supports intent to aid a weapon assault.
Did defendant adequately preserve challenging the law applied (natural and probable consequences) and related sufficiency?	State asserts preservation and proper application of law; Fichter was not misapplied.	Baranovich argues lack of intent to weaponize and improper reliance on natural-and-probable-consequences doctrine.	Yes, preservation was adequate; the doctrine was not required for this sufficiency finding.

State v. Fichter, 226 Or. 526 (Or. 1961) (recognizes or critiques natural and probable consequences doctrine)
State v. Lopez-Minjarez, 236 Or. App. 270 (Or. App. 2010) (limits use of natural and probable consequences in accomplice liability)
State v. Viranond, 346 Or. 451 (Or. 2009) (explains standard for appellate review of sufficiency in bench trial)