Darrell Bodely (defendant) entered a supermarket, grabbed $75 from a cash register, and fled the store. Several supermarket employees chased Bodely into the parking lot. As Bodely attempted to drive away in his car, Joseph Andre, who was also in the parking lot, attempted to stop Bodely by putting an arm through the driver’s window. Bodely jerked the car sharply to the left, hitting Andre and causing him to injure his head on the pavement. Andre died as a result. Bodely was charged with burglary and first-degree murder pursuant to the felony-murder rule. After a trial, Bodely was convicted on all counts. Bodely appealed the murder conviction, arguing that he could not be charged under the felony-murder rule, because the burglary ended once he left the supermarket.