Adams (defendant), with two accomplices, broke into a gas station, took items out of the store to steal, and went back inside for more. Police officers, including Clarence Green, pulled up to the store while the burglary was ongoing. Adams and the accomplices ran from the store, and the police officers chased them. During the chase, someone shot and killed Green. The State of Missouri (plaintiff) charged Adams with first-degree felony murder. The trial court instructed the jury that any homicide committed in the perpetration or attempted perpetration of a burglary is first-degree felony murder and that the perpetration of burglary includes carrying away stolen property and continues until the property has been reduced to the unmolested dominion of the burglars. The jury convicted Adams, and he appealed.