People v. Cavitt
Supreme Court of California
14 Cal. Rptr. 3d 281 (2004)
Cavitt (defendant) and Williams robbed and tied up Betty, the stepmother of Cavitt's girlfriend Mianta, as part of a planned robbery, leaving her bound and beaten; Betty later died of asphyxiation while the perpetrators (including Mianta, also left tied up to appear a victim) were still on the scene or shortly after their escape. At trial, the defense argued Mianta herself killed Betty out of personal animus after the others left, and requested (unsuccessfully) a jury instruction requiring the killing be "in furtherance of" the felony for felony murder to apply; Cavitt and Williams were convicted, and the convictions were affirmed on appeal before reaching the state supreme court.
Whether the felony murder rule applies to a non-killer felon if there is both a causal relationship and a temporal relationship between the underlying felony and the act resulting in death.