Does the escape rule apply to a murder committed to a perfect escape from lawful custody?
California, United States of America
The following excerpt is from People v. Wilkins, S190713 (Cal. 2013):
3. People v. Bigelow applied the escape rule to determine the scope of the special circumstance of murder committed to " 'perfect . . . an escape from lawful custody,' " and concluded that an escapee who had remained at liberty for 12 days and traveled over a thousand miles had reached a place of temporary safety. (People v. Bigelow, supra, 37 Cal.3d at p. 751; see id. at p. 754.)
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