California, United States of America
The following excerpt is from People v. Berryman, 25 Cal.Rptr.2d 867, 6 Cal.4th 1048, 864 P.2d 40 (Cal. 1993):
The first relates to independent felonious purpose. The felony-murder special circumstance requires that the "defendant [must] commit[ ] the act resulting in death in order to advance an independent felonious purpose." (People v. Bonin (1989) 47 Cal.3d 808, 850, 254 Cal.Rptr. 298, 765 P.2d 460.)
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