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This term is used in California and simply denotes the felony murder doctrine. The unlawful killing of a human being, whether intentional, unintentional or accidental, which occurs as a direct causal result of the commission of or attempt to commit a felony inherently dangerous to human life under circumstances or conditions which cause or create risk of great bodily harm, serious mental or physical illness, or death, and where there was in the mind of the perpetrator the specific intent to commit such crime, is murder of the second degree. In the application of the second degree felony-murder analysis courts are guided by the bipartite standard articulated in People v. Henderson,19 Cal.3d 86. In Henderson, it was stated that a reviewing court should look first to the primary element of the offense at issue, then to the 'factors elevating the offense to a felony,' to determine whether the felony, taken in the abstract, is inherently dangerous to human life (id., at p. 94), or whether it possibly could be committed without creating such peril. (Ibid.; accord, People v. Lopez, supra, 6 Cal.3d 45.) In this examination a court is required to view the statutory definition ...

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