A robber walked into a jewelry store, fired a gun into the air, and told everyone to get down on the ground.
While the robber cleared out the jewelry displays and the cash register, an employee tripped the silent alarm. The police soon surrounded the store. While the robber was trying to figure out how he was going to get out of the store, an elderly female hostage panicked, running to the front door of the store. The robber fired at the elderly woman but missed. However, the defendant's gunfire caused the police to respond by firing their weapons into the store, accidentally killing the woman. The police apprehended the robber. This jurisdiction follows the proximate cause theory of felony murder.

Should the robber be convicted of murder for the elderly woman's death?