People v. Burton
Supreme Court of California
491 P.2d 793 (1971)
Relevant factsFree
Burton killed a victim during an armed robbery and was convicted of first-degree felony murder, arguing on appeal that because armed robbery necessarily involves assault with a deadly weapon, precedent excluding assault-based felonies (where the assault itself was the sole purpose of the conduct resulting in death) from supporting felony-murder instructions should likewise bar armed robbery from doing so.
IssueFree
Whether deaths resulting from felonies undertaken for a purpose independent of the homicide support a charge of felony murder.