Can a defendant be held liable for the death of his accomplice under section 1170.95 of the California Criminal Code?

Appellants cannot seek relief under the felony-murder provision of section 1170.95. They were convicted of provocative act murder, not felony murder. "When someone other than the defendant or an accomplice kills during the commission or attempted commission of a crime, the defendant is not liable under felony-murder principles but may nevertheless be prosecuted for murder under the provocative act doctrine.... Under the felony-murder rule, if an accomplice is killed by a crime victim and not by the defendant, the defendant cannot be held liable for the accomplice's death. [Citations.] The provocative act doctrine is not so limited. Under the provocative act doctrine, ... the killing is attributable, not merely to the commission of a felony, but to the intentional act of the defendant or his accomplice committed with conscious disregard for life. " ( People v. Gonzalez (2012) 54 Cal.4th 643, 654-655, 142 Cal.Rptr.3d 893, 278 P.3d 1242 ( Gonzales ).)