California, United States of America
The following excerpt is from People v. Pulido, 15 Cal.4th 713, 63 Cal.Rptr.2d 625, 936 P.2d 1235 (Cal. 1997):
3 A killing committed by a robber during his or her flight from the scene of the crime, and before reaching a place of temporary safety, comes within section 189. (People v. Salas (1972) 7 Cal.3d 812, 820-824, 103 Cal.Rptr. 431, 500 P.2d 7.)
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