What is the test for establishing a felony-murder rule?

"Under the felony-murder rule, a strict causal or temporal relationship between the felony and the murder is not required; what is required is proof beyond a reasonable doubt that the felony and murder were part of one continuous transaction. [Citation.] This transaction may include a defendant's flight after the felony to a place of temporary safety. [Citations.]" (People v. Young (2005) 34 Cal.4th 1149, 1175.)

"`Whether in a given case the [defendant] has reached a place of safety is ordinarily a question of fact; a jury's implied finding on the issue will be upheld so long as supported by substantial evidence. [Citations.]' [Citation.]" (People v. Cummins (2005) 127 Cal.App.4th 667, 679-680, quoting People v. Carter (1993) 19 Cal.App.4th 1236, 1251.)