It has been abolished by Hawaii, Kentucky, and Michigan. Most states limit the rule to deaths caused negligently during the commission of a felony. While California uses the enumerated felonies approach, Texas requires that the defendant committed an act clearly dangerous to human life during the commission of a felony, and Alabama uses both approaches. All jurisdictions have limited the application of the felony murder rule to those who have committed or attempted certain felonies. The traditional predicate felonies (felonies which are either enumerated or considered "inherently dangerous") are "arson, burglary, robbery, rape, and kidnapping". Inherently dangerous felony limitation The inherently dangerous felony approach is the most popular limitation on the rule. It is further divided into two subtypes. The majority of jurisdictions using this limitation look at whether the felony was inherently dangerous by looking at the facts of the case before the court, i.e. "based on the manner in which the felony was committed." The abstract approach which looks at the elements of the predicate felony in the abstract and not the particular facts of the case before the court is the minority approach. In California, examples of felonies that have been identified as "inherently dangerous" in the abstract include kidnapping and arson of a motor vehicle. While felonies that have not been found to be inherently dangerous in the abstract include prison escape and grand theft. Felonies that endanger the physical health of the victim are excluded from being a predicate felonies in jurisdictions that follow the inherently dangerous felony approach under the merger limitation. It is reasoned that such felonies (like assault) have been designated as a lesser form of homicide by state legislatures, and therefore most jurisdictions punish intentional killings as voluntary manslaughter "if committed with provocation or extreme emotional disturbance" because otherwise it would invalidate the legislature's choice of punishment. An example of the merger doctrine in most jurisdictions is this: A person who commits burglary with the intent to steal inside the dwelling and who, during this process, comes across and murders the homeowner will be found guilty under the felony murder rule. However, someone who commits burglary with the intent to kill another inside the dwelling does not fall under the felony murder rule as the felony is merged. Complicity Doctrine Cofelons are individuals who commit a felony together, such as armed robbery. Under the complicity doctrine, an individual who is a