Felony Murder Rule In American Jurisprudence
Felony Murder Rule: Overview
The Felony Murder Rule is a legal doctrine in many U.S. states that allows a defendant to be charged with murder if a death occurs during the commission or attempted commission of a felony, even if the defendant did not intend to kill or cause the death.
Key Principles:
During the commission of a felony: The murder charge applies if the death happens during the felony itself, not before or long after.
Felonies covered: Typically serious felonies like robbery, burglary, arson, rape, or kidnapping. These are often called “inherently dangerous felonies.”
Strict liability for death: The defendant’s intent to kill is irrelevant; the mere participation in the felony that leads to death suffices.
Policy rationale: It discourages dangerous felonies by holding felons strictly responsible for any lethal consequences.
Case Law Examples
1. People v. Washington (1965)
Court: California Supreme Court
Facts:
Defendant Washington was involved in a robbery during which a victim died accidentally. Washington did not personally kill the victim but was convicted under the felony murder rule.
Legal Issues:
Whether the defendant could be held liable for murder without intent to kill
Application of felony murder when death is accidental but occurs during felony
Ruling:
The court upheld the conviction, ruling that if a death occurs during the commission of a felony, all participants can be held liable for felony murder, even if the death was unintended or accidental.
Significance:
This case reinforced the principle of strict liability under the felony murder rule in California and similar jurisdictions.
2. Enmund v. Florida (1982)
Court: United States Supreme Court
Facts:
Enmund was a getaway driver during a robbery where his accomplices killed the victims. He did not directly participate in the killing or intend it.
Legal Issues:
Whether the death penalty was constitutional for someone who did not kill or intend to kill under felony murder
Limits on culpability under the felony murder rule
Ruling:
The Court ruled that imposing the death penalty on a defendant who did not kill, attempt to kill, or intend to kill violated the Eighth Amendment’s prohibition on cruel and unusual punishment.
Significance:
This decision limited the scope of felony murder by emphasizing the need for some culpability related to the killing before imposing the harshest penalties.
3. Tison v. Arizona (1987)
Court: United States Supreme Court
Facts:
Tison brothers helped their father and another inmate escape prison. During the escape, the inmates killed a family. The brothers did not commit the killings but were heavily involved in the felony.
Legal Issues:
Whether major participation and reckless indifference to human life justify the death penalty under felony murder
Extent of liability for felony murder defendants
Ruling:
The Court held that defendants who are major participants in a felony and show reckless indifference to human life can be sentenced to death, even if they did not personally kill.
Significance:
Clarified that felony murder liability and punishment depend on the defendant’s level of participation and mindset.
4. State v. Sophophone (1995)
Court: Washington State Supreme Court
Facts:
Sophophone was a getaway driver during an armed robbery; during the robbery, a victim was shot and killed by an accomplice.
Legal Issues:
Whether Sophophone could be convicted of felony murder despite no direct involvement in the killing
Application of felony murder to accomplices
Ruling:
The court affirmed the felony murder conviction, emphasizing that all participants in a dangerous felony are liable for deaths resulting from the felony.
Significance:
Reinforced the principle that accomplices share liability under the felony murder rule.
5. People v. Stamp (2010)
Court: New York Court of Appeals
Facts:
During a burglary, the defendant’s accomplice accidentally killed a homeowner. The defendant was charged with felony murder.
Legal Issues:
Whether felony murder applies if the death was accidental and the defendant did not directly cause it
Limits of foreseeability and proximate cause in felony murder
Ruling:
The court upheld the felony murder conviction, ruling that deaths resulting from the felony, even if accidental, fall under the felony murder rule.
Significance:
This case emphasized foreseeability and the connection between felony acts and resulting deaths.
Summary of Legal Principles from These Cases
Strict liability for deaths during felonies: Defendants can be held liable for murder even without intent to kill.
Limits on punishment: The U.S. Supreme Court limits death penalty application to defendants with significant participation or intent related to the killing.
Accomplice liability: All participants in the felony can be charged with felony murder if a death results.
Foreseeability and causation: The death must be a foreseeable result of the felony for liability to attach.
Policy rationale: The rule is designed to deter dangerous felonies by holding criminals responsible for consequences.
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