Can a conviction under felony-murder rule be overturned where the victim suffered a heart attack during a robbery?

MultiRegion, United States of America

The following excerpt is from Brown v. Bunnell, 26 F.3d 129 (9th Cir. 1994):

People v. Stamp, 82 Cal.Rptr. 598, 603 (Ct.App.1969) (upholding conviction under felony-murder rule where victim suffered heart attack during robbery), cert. denied, 400 U.S. 819 (1970).

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