People v. Washington
Citation
62 Cal. 2d 777 (1965)
Facts
Stub — to be completed.
Issue
Stub — to be completed.
Holding
Stub — to be completed.
Rule
Felony murder liability does not extend to a killing committed by the victim of the felony in resistance to the felony (the “shield” or “provocative act” doctrine); the defendant must be the proximate cause of the killing.
Significance
Established the “agency rule” in California felony murder: only killings committed by the felons themselves (or their agents) trigger felony murder liability — killings by victims or police in response to the felony do not.