California, United States of America
The following excerpt is from People v. Maldonado, B228175 (Cal. App. 2012):
4. The merger doctrine, set forth in People v. Ireland (1979) 70 Cal.2d 522, 539, precludes the application of the second degree felony-murder rule to an unintentional killing that occurs during the commission of a felony if the felony is an integral part of the homicide.
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