California, United States of America
The following excerpt is from People v. Slaughter, 200 Cal.Rptr. 448, 35 Cal.3d 629, 677 P.2d 854 (Cal. 1984):
However, it has long been recognized that the felony-murder doctrine is "a highly artificial concept," one which "anachronistically resurrects from a bygone age a 'barbaric' concept that has been discarded in the place of its origin." (People v. Phillips (1966) 64 Cal.2d 574, 582, 583, fn. 6, 51 Cal.Rptr. 225, 414 P.2d 353.) The rule "not only 'erodes the relation between criminal liability and moral culpability' but also is usually unnecessary for conviction ...." (People v. Satchell (1971) 6 Cal.3d 28, 33, 98 Cal.Rptr. 33, 489 P.2d 1361.)
Consequently, the felony-murder rule is a disfavored doctrine, and the prior decisions of this court "make it clear we hold no brief for the ... rule." 23 In deciding whether felony-murder principles are applicable in various specific factual settings, the court has consistently "sought to insure that the ... doctrine be given the narrowest possible application consistent with its ostensible purpose ...." (People v. Satchell, supra, 6 Cal.3d at p. 34, 98 Cal.Rptr. 33, 489 P.2d 1361.)
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