California, United States of America
The following excerpt is from People v. Caldwell, 203 Cal.Rptr. 433, 36 Cal.3d 210, 681 P.2d 274 (Cal. 1984):
In People v. Washington, supra, 62 Cal.2d at page 783, 44 Cal.Rptr. 442, 402 P.2d 130, this court held that the felony-murder rule does not apply to killings not physically committed by the felons themselves. Today's majority opinion takes a big step toward overturning that sound holding.
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