People v. Wilson (1969)

People v. Wilson (1969) 1 Cal.3d 431, was a case involving a homicide occurring in the course of a burglary, where the only basis for finding a felonious entry was the intent to commit an assault with a deadly weapon. (Id. at p. 440.) The court stated: "When, as here, the entry would be nonfelonious but for the intent to commit the assault, and the assault is an integral part of the homicide and is included in fact in the offense charged, utilization of the felony-murder rule extends that doctrine 'beyond any rational function that it is designed to serve.'" (Ibid.) The court explained: "'The purpose of the felony-murder rule is to deter felons from killing negligently or accidentally by holding them strictly responsible for killings they commit.' Where a person enters a building with an intent to assault his victim with a deadly weapon, he is not deterred by the felony-murder rule. That doctrine can serve its purpose only when applied to a felony independent of the homicide." (Ibid.)