See Hanright , 466 Mass. at 307-310, 994 N.E.2d 363 ; Commonwealth v. Richards , 363 Mass. 299, 307, 293 N.E.2d 854 (1973) ("A broad conception of complicity is indeed at work in the special field of so called felony-murder ..."). More recently, in Commonwealth v. Tejeda , 473 Mass. 269, 277, 41 N.E.3d 721 (2015), we considered the continued viability of the common-law felony-murder rule, but did not reach the issue. Discussing the scope of vicarious liability, we noted that felony-murder is an exception to the general rule that "[o]ne is punished for his own blameworthy conduct, not that of others" (citation omitted).

In this consolidated appeal from his convictions and from the denial of his motion for a new trial, the defendant argues, among other things, that the conviction of felony-murder cannot stand because Collins, the defendant's accomplice, was killed during a struggle with the intended robbery victim, and the theory of felony-murder thus is inapplicable. See Commonwealth v. Tejeda, 473 Mass. 269, 279, 41 N.E.3d 721 (2015) ; Commonwealth v. Balliro, 349 Mass. 505, 515, 209 N.E.2d 308 (1965), S.C., 370 Mass. 585, 350 N.E.2d 702 (1976). The defendant also was convicted of armed assault with intent to rob and assault and battery by means of a dangerous weapon causing serious bodily injury, with respect to the wounding of Dancy, as well as unlawful possession of a firearm and unlawful possession of ammunition.

After a jury trial, the defendant, Robinson Tejeda, was convicted of armed robbery and other charges. This court affirmed his convictions in Commonwealth v. Tejeda, 473 Mass. 269, 281-282, 41 N.E.3d 721 (2015). The defendant's convictions stem from his involvement in the robbery of a man from whom the defendant and two friends had arranged to buy marijuana.

Campbell, 7 Allen at 541-542, 543. See Brown, 477 Mass. at 828-829, 81 N.E.3d 1173 (Gants, C.J., concurring) (discussing Campbell’s limitations on liability for death that occurred during commission of underlying felony); Commonwealth v. Tejeda, 473 Mass. 269, 273, 41 N.E.3d 721 (2015), S.C., 481 Mass. 794, 119 N.E.3d 743 (2019) (same). The Campbell court observed that the defendant could be held responsible for the actions of fellow rioters only if the killing was "in furtherance of a common [unlawful] object[ive]."

. Commonwealth v. Tejeda, 473 Mass. 269, 272 (2015), S.C., 481 Mass. 794 (2019). Thus, where a defendant's felonious intent is in question, involuntary manslaughter comes into play.

In order for a jury to find a defendant guilty of joint venture felony-murder with armed home invasion as the predicate felony, the Commonwealth is required to establish beyond a reasonable doubt that the defendant participated in committing armed home invasion as a joint venturer and that the victims were killed in furtherance of that crime. See, e.g., Commonwealth v. Tejeda, 473 Mass. 269, 272-273 (2015). To prove a joint venture, the Commonwealth is required to show that the defendant knowingly participated in the commission of the crime charged with the intent required for the offense.

In order for a jury to find a defendant guilty of joint venture felony-murder with armed home invasion as the predicate felony, the Commonwealth is required to establish beyond a reasonable doubt that the defendant participated in committing armed home invasion as a joint venturer and that the victims were killed in furtherance of that crime. See, e.g., Commonwealth v. Tejeda, 473 Mass. 269, 272-273, 41 N.E.3d 721 (2015). To prove a joint venture, the Commonwealth is required to show that the defendant knowingly participated in the commission of the crime charged with the intent required for the offense.

In Brown, we also observed that Michigan had already abolished the felony-murder rule under its common law. Id. at 833, 81 N.E.3d 1173 (Gants, C.J., concurring), citing Commonwealth v. Tejeda, 473 Mass. 269, 277 n.9, 41 N.E.3d 721 (2015) (discussing People v. Aaron, 409 Mich. 672, 727-729, 299 N.W.2d 304 [1980] ). We note that following the abolition of the felony-murder rule in Michigan, appellate courts in that State have rejected the claim that the merger doctrine is still applicable.

In 2012, Robinson Tejeda participated in an armed robbery that went awry, and during which one of his coventurers was shot and killed. The details of the crime are set forth in Commonwealth v. Tejeda, 473 Mass. 269, 270 (2015). For present purposes, it is material that the defendant remained outside in a vehicle while his coventurers, Stephen Etienne and Christopher Pichardo, entered a building to meet a drug dealer.

We note that there is no uniformity regarding felony-murder within the United States: some States have abolished the crime, and others have significantly departed from the traditional formulation, like that in Massachusetts. Commonwealth v. Tejeda , 473 Mass. 269, 277 n.9, 41 N.E.3d 721 (2015). The Model Penal Code has abandoned this formula, "requiring the homicide to be purposeful, knowing, or reckless in order to constitute murder, but providing for a rebuttable presumption of recklessness where the homicide occurred during the commission of certain felonies.