California, United States of America
The following excerpt is from People v. Hayes, C077151 (Cal. App. 2017):
For burglary murder purposes, the jury had to find the killing occurred "as a result of the commission of the crimes of robbery or burglary and where there was in the mind of the perpetrator the specific intent to commit such crime." Thus, the jury had to find defendant intended to steal as part and parcel of the killing. Generally, "When one kills and then takes substantial property from the victim, a reasonable jury can ordinarily find the killing was for the purpose of taking the property." (People v. Johnson (2015) 60 Cal.4th 966, 988.) That suffices here.
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