What are the implications of a first degree felony murder conviction for the purpose of reducing the sentence to life imprisonment?

Appellant contends that her sentence violates the cruel or unusual punishment prohibition of the state Constitution (Cal.Const., art. I, 17) and that the trial court erred in denying her request for jury instructions on lesser included offenses to the murder. Both arguments are based on People v. Dillon (1983) 34 Cal.3d 441, 194 Cal.Rptr. 390, 668 P.2d 697. Dillon held that the penalty for first degree felony murder is subject to the prohibition against cruel or unusual punishments, which includes the rule that a punishment is impermissible if grossly disproportionate to the offense or the culpability of the offender.