California, United States of America
The following excerpt is from People v. Kimbrough, A144991 (Cal. App. 2017):
Theft from a person is not a felony listed in Penal Code section 189, and thus not an offense that qualifies for first degree felony murder. Nor is it a felony inherently dangerous to human life, and thus not an offense that qualifies for second degree felony murder. (People v. Morales (1975) 49 Cal.App.3d 134, 143-144.)
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