## Facts

- James Freddie Cavitt and Robert Nathaniel Williams planned a home-invasion robbery with Mianta McKnight, targeting Mianta’s stepmother, Betty McKnight.
- The plan called for entering the home, surprising Betty, restraining her, and stealing jewelry and other property.
- On December 1, 1995, defendants entered the home, covered Betty’s head with a sheet, and bound her wrists and ankles with rope and duct tape, leaving her hog-tied and face down on a bed with labored breathing.
- Defendants stole guns, jewelry, and other valuables and left the residence; they also staged Mianta as a victim by pretending to tie her up.
- After defendants left, Mianta freed herself and reported the crime; Betty was later found dead from asphyxiation.
- The prosecution presented evidence supporting that defendants’ restraint of Betty caused her death; the defense presented evidence suggesting Mianta intentionally suffocated Betty after defendants had left, for reasons independent of the robbery-burglary and after defendants had reached temporary safety.

## Issues

1. What standard governs felony-murder liability for a nonkiller when a confederate may have committed the lethal act for reasons arguably independent of the felony.
2. Whether the jury must be instructed that felony murder does not apply if the killing was unrelated to the felony and/or occurred after defendants reached a place of temporary safety.

## Decision

- The California Supreme Court affirmed both defendants’ first-degree felony-murder convictions and the burglary-murder and robbery-murder special-circumstance findings.
- The court held felony murder does not apply to nonkillers when the act causing death is completely unrelated to the underlying felony other than coinciding in time and place.
- The court rejected defendants’ proposed requirement that, for nonkiller liability, the killing must be “in furtherance” of (i.e., intended to advance) the felony.
- The court concluded that, although the instructions did not perfectly state the court’s later-articulated standard, they were not misleading in a way requiring reversal and any deficiency was nonprejudicial on this record.

## Legal Principles

- For nonkiller felony-murder liability under Penal Code § 189, the prosecution must prove both:
  - A causal relationship: a “logical nexus,” beyond mere coincidence of time and place, between the homicidal act and the underlying felony the defendant committed or attempted; and
  - A temporal relationship: the felony and the homicidal act were part of one continuous transaction.
- The continuous-transaction requirement limits felony murder to killings occurring during the felony’s commission and immediate flight, and excludes killings after perpetrators have reached a place of temporary safety.
- California felony murder does not require proof that the killer acted with an intent to further or advance the felony; relatedness is addressed through the logical-nexus requirement rather than the killer’s purpose.

## Conclusion

The court affirmed felony-murder convictions and clarified that a nonkiller is liable only when the killing is connected to the felony by a logical nexus and occurs within the felony’s continuous transaction; mere coincidence of time and place is insufficient, and an “in furtherance” intent requirement is not part of California’s felony-murder rule.


People v. Cavitt, 33 Cal. 4th 187, 91 P.3d 222 (Cal. 2004)