California, United States of America
The following excerpt is from People v. Sarber, 7 Cal.App.4th 1336, 9 Cal.Rptr.2d 568 (Cal. App. 1992):
7 Similarly, courts have drawn a distinction between simple and forcible escape in determining what felonies are or are not inherently dangerous to human life for purposes of implementation of the second-degree felony murder rule. (People v. Lynn (1971) 16 Cal.App.3d 259, 269-270, fn. 9, 94 Cal.Rptr. 16 [forcible escape a felony inherently dangerous to human life]; People v. Lopez (1971) 6 Cal.3d 45, 51, 98 Cal.Rptr. 44, 489 P.2d 1372 [simple escape not a felony inherently dangerous to human life].)
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