People v. Howard
Supreme Court of California
104 P.3d 107 (2005)
After an officer signaled him to pull over for a missing license plate, Howard (defendant) fled at high speed, running stop signs and lights, before running a red light and fatally crashing into another car; he was convicted of fleeing from an officer while driving with willful or wanton disregard for others' safety, and this conviction served as the predicate felony for a second-degree felony-murder charge based on the death. An intermediate appellate court had previously found this same offense inherently dangerous under the pre-amendment statute, but the statute was later amended to add a new subdivision covering additional violations.
Whether a felony offense remains inherently dangerous to human life in the abstract, for felony-murder purposes, when a statutory amendment expanded its definition to include violations that can be committed without endangering anyone.