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It refers to the felony murder rule. That means that any death that is a result of the commission of a felony is going to be murder.
See Stateline.org report, which includes a list of states with felony murder rule:
http://www.stateline.org/live/details/story?contentId=333117
Felony. Serious felony.
Felony.
There is no such thing as non-felony murder...