California, United States of America
The following excerpt is from People v. Pearch, 229 Cal.App.3d 1282, 280 Cal.Rptr. 584 (Cal. App. 1991):
Most recently, the court in People v. Ordonez, supra, 226 Cal.App.3d 1207, 277 Cal.Rptr. 382, a case holding killing during a kidnapping for ransom, extortion or reward was second degree felony murder, noted:
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