California, United States of America
The following excerpt is from People v. Alvarez, F069390 (Cal. App. 2016):
Defendant argues the threats to Backhaus and her son were part of her commission of the robbery because the crime was still in progress since the three suspects had not yet reached a place of temporary safety. " 'Under the escape rule,... "robbery is said to continue through the escape to a place of temporary safety, whether or not the asportation of the loot coincides with the escape." ' [Citation.] The purpose of the escape rule is to measure the duration of a robbery, in order to determine whether a killing or some other act has occurred in the perpetration or commission of the robbery. [Citation.]" (People v. Rodriguez (2015) 235 Cal.App.4th 1000, 1007, italics in original.)
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