context: With one exception, the courts not allowing felony murder to be based on assault-motivated - burglaries - construed - differently phrased statutes. Those statutes required that death occur both in the course of and in furtherance of the burglary.
citation_a.signal: no signal
citation_a.identifier: 818 A.2d 913, 913
citation_a.parenthetical: "the murder, although 'in the course of the burglary, was not carried out 'in furtherance of it"
citation_a.sentence: Williams, 818 A.2d at 913 ("the murder, although 'in the course of the burglary, was not carried out 'in furtherance of it"); Sellers, 749 S.W.2d at 671 (similar); cf. People v. Cahill, 2 N.Y.3d 14, 777 N.Y.S.2d 332, 809 N.E.2d 561, 587-90 (2008) (relying on conjunctive statutory language to hold that burglary committed with intent to murder cannot elevate intentional murder to capital murder).
citation_b.signal: cf.
citation_b.parenthetical: relying on conjunctive statutory language to hold that burglary committed with intent to murder cannot elevate intentional murder to capital murder
citation_b.sentence: Williams, 818 A.2d at 913 ("the murder, although 'in the course of the burglary, was not carried out 'in furtherance of it"); Sellers, 749 S.W.2d at 671 (similar); cf. People v. Cahill, 2 N.Y.3d 14, 777 N.Y.S.2d 332, 809 N.E.2d 561, 587-90 (2008) (relying on conjunctive statutory language to hold that burglary committed with intent to murder cannot elevate intentional murder to capital murder).