California, United States of America
The following excerpt is from People v. Bell, D072748 (Cal. App. 2019):
13. The provocative act murder doctrine therefore may apply when the felony-murder doctrine does not apply (e.g., when an accomplice is killed by a crime victim rather than by the defendant). (People v. Briscoe (2001) 92 Cal.App.4th 568, 581 (Briscoe).)
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