California, United States of America
The following excerpt is from People v. Okumura, C084467 (Cal. App. 2019):
The escape rule provides a killing that occurs during a robbery will be deemed murder unless it occurs after the robber has reached a place of temporary safety, that is, has eluded pursuers, and is in unchallenged possession of the stolen property. (See People v. Boss (1930) 210 Cal. 245, 250-251.) If the defendant exercises continuous
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