California, United States of America
The following excerpt is from People v. Laursen, 22 Cal.App.3d 1033, 99 Cal.Rptr. 841 (Cal. App. 1972):
The doctrine was stated in the early felony-murder case of People v. Boss (1930) 210 Cal. 245, 250-251, 290 P. 881, which involved a murder prosecution as a result of the defendants' having killed a person who was pursuing them in their flight from the scene of a robbery they had committed.
The common law felony-murder doctrine was codified in Penal Code section 189 and applies to a homicide committed in the 'perpetration' of robbery, rather than to 'any person who kidnaps . . . to commit robbery' (Pen.Code, 209). As applied in the felony-murder context, it has always been enough to show that the felony and the killing are part of a continuous transaction (People v. Chavez (1951) 37 Cal.2d 656, 234 P.2d 632). In that case the court restated the law:
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