Homicide Under Federal And State Law
Overview of Homicide
Homicide refers to the killing of one human being by another. It can be lawful (e.g., self-defense) or unlawful. Unlawful homicide includes:
Murder (first degree, second degree)
Manslaughter (voluntary and involuntary)
Felony murder
Both federal and state laws criminalize homicide, but prosecution often occurs at the state level unless the homicide violates federal statutes (e.g., killing a federal officer, terrorism-related killing).
1. Murder in the First Degree: State Law — People v. Anderson (California, 1968)
Facts:
Anderson was convicted of first-degree murder for a premeditated killing.
The case involved deliberation on whether the killing was willful, deliberate, and premeditated.
Legal Issues:
Under California law, first-degree murder requires intent and premeditation.
The question was how long premeditation must occur to qualify.
Judgment:
The California Supreme Court ruled that premeditation can occur in a brief moment if the defendant had time to form intent.
Anderson’s conviction was upheld.
Significance:
This case clarified that premeditation does not require a lengthy time but any reflection before the act.
Influences many state courts in defining first-degree murder.
2. Federal Murder Statute: United States v. Booker (2005)
Facts:
Booker was convicted of murder under federal law during a drug trafficking crime.
The case reached the Supreme Court in relation to sentencing guidelines for murder convictions.
Legal Issues:
Application of federal sentencing guidelines and the right to jury trial in determining facts increasing sentences.
Judgment:
The Supreme Court ruled that sentencing guidelines must be advisory, not mandatory.
This affected federal murder sentencing but did not overturn the murder conviction.
Significance:
Though not about guilt, it affected how federal murder sentences are imposed.
Reinforced constitutional protections in homicide cases.
3. Voluntary Manslaughter: State v. Mullaney (Maine, 1975)
Facts:
Mullaney was charged with murder but claimed provocation (heat of passion).
Maine law required the defendant to prove provocation to reduce murder to manslaughter.
Legal Issues:
The constitutionality of requiring the defendant to prove provocation (burden of proof) was challenged.
Judgment:
The U.S. Supreme Court held that the prosecution must prove beyond a reasonable doubt every element of the crime, including absence of provocation.
The law shifting the burden to defendant was unconstitutional.
Significance:
Established that in homicide cases, prosecution must prove intent and lack of provocation.
A cornerstone for voluntary manslaughter defenses.
4. Felony Murder Rule: People v. Stamp (New York, 1969)
Facts:
Stamp was charged under the felony murder rule after a death occurred during a robbery.
He argued he did not intend to kill.
Legal Issues:
Whether a killing during commission of a felony, regardless of intent, constitutes murder.
Judgment:
The court upheld the felony murder doctrine: any death during the commission of a felony is murder.
Stamp was convicted of murder despite lack of intent.
Significance:
Reinforced the felony murder rule in state law.
Controversial for imposing strict liability for homicide during felonies.
5. Federal Capital Murder Case: United States v. Timothy McVeigh (1997)
Facts:
Timothy McVeigh was convicted of the Oklahoma City bombing, killing 168 people.
Charged under federal statutes for capital murder and terrorism.
Legal Issues:
Application of federal capital murder laws.
Whether the death penalty was applicable.
Judgment:
McVeigh was found guilty of capital murder.
He was sentenced to death and executed in 2001.
Significance:
One of the most significant federal homicide prosecutions.
Showcased the use of federal laws in mass casualty homicide cases.
Key Legal Principles in Homicide Prosecutions:
Intent and Premeditation: Key in distinguishing murder degrees.
Provocation: Can reduce murder to manslaughter if proven.
Felony Murder Rule: Holds felons strictly liable for deaths during felonies.
Federal vs. State Jurisdiction: Most homicides tried in state courts unless federal law applies.
Due Process Protections: Burden of proof lies with prosecution for every element.
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