California, United States of America
The following excerpt is from People v. George, C082626 (Cal. App. 2018):
As we are unable to determine whether the jury's verdict on felony murder is based on a legally valid theory, we must reverse the conviction and its associated special circumstance and remand for retrial at the option of the People. (People v. Guiton (1993) 4 Cal.4th 1116, 1129.)8
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