California, United States of America
The following excerpt is from People v. Owens, C069838, C069853, C069856 (Cal. App. 2013):
The robbery-murder (analogously, the burglary-murder) special circumstance applies to a murder committed in the course of a robbery, not to a robbery committed in the course of a murder. ( 190.2, subd. (a)(17); People v. Marshall (1997) 15 Cal.4th 1, 41.)
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