When applying the felony murder rule under 18 U.S.C. § 1(a) to the crime of carjacking, what must a defendant show to establish that he has reached a point of 'temporary safety' separating the carjacking itself from subsequent events?

QUESTION PRESENTED When applying the felony murder rule under 18 U.S.C. § 1(a) to the crime of carjacking, what must a defendant show to establish that he has reached a point of “temporary safety” separating the carjacking itself from subsequent events? i