In a felony-murder case, what is the current state of the law on the defense of imperfect self-defense?

In People v. Loustaunau (1986) 181 Cal.App.3d 163, 226 Cal.Rptr. 216, the court recognized that a claim of imperfect self-defense is inapplicable in a felony-murder case. In that case, the defendant contended imperfect self-defense should reduce felony murder to manslaughter. The court rejected [67 Cal.App.4th 9] this assertion, noting "... an honest but unreasonable belief in self-defense negates malice aforethought. [Citation.] In felony murder, on the other hand, malice aforethought is not required." (Id. at p. 170, 226 Cal.Rptr. 216.)

In a similar case, People v. Anderson (1991) 233 Cal.App.3d 1646, 285 Cal.Rptr. 523, defendant was charged with first degree felony murder and the trial court refused to instruct on the defense of imperfect duress. The appellate court affirmed, noting: "Even if the defense of imperfect duress could negate malice aforethought, malice aforethought is not an element of either felony murder or robbery. Hence, a defense tending to negate malice aforethought is simply irrelevant and provides no defense at all to felony murder." (Id. at p. 1666, 285 Cal.Rptr. 523.)