Felony Murder Rule Accomplice Liability

In People v. Pulido (1997) 15 Cal. 4th 713 63 Cal. Rptr. 2d 625, 936 P.2d 1235, the Supreme Court acknowledged that its past "descriptions of an accomplice's liability under the felony-murder rule have limited complicity to killings occurring while the killer was acting in furtherance of a criminal purpose common to himself and the accomplice see People v. Washington (1965) 62 Cal. 2d 777 44 Cal. Rptr. 442, 402 P.2d 130; People v. Vasquez (1875) 49 Cal. 560, or while the killer and accomplice were jointly engaged in the felonious enterprise see People v. Martin (1938) 12 Cal. 2d 466 85 P.2d 880; People v. Perry (1925) 195 Cal. 623 234 P. 890." ( People v. Pulido, supra, 15 Cal. 4th at p. 719.) Under the first line of cases, accomplice liability arises when the killing is committed " 'in furtherance of their common purpose to rob." ( People v. Pulido, supra, 15 Cal. 4th at p. 721.) Under the second line, "the killing need have no particular causal or logical relationship to the common scheme of robbery; accomplice liability attaches, instead, for any killing committed while the accomplice and killer are 'jointly engaged' in the robbery." ( Id. at p. 722.)