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King v. State

    Brief Fact Summary.

    Defendant appeals a conviction of murder for shooting into a car and killing a man with whom he had argued earlier.

     

    Synopsis of Rule of Law.

    Criminal homicide constitutes murder when it is committed recklessly and in a manner that manifests extreme indifference to human life.

     

    Facts.

    On November 22, 1984, Christopher Doyle King (Defendant) argued with Dwight Lee Reeves at a nightclub. Later that night, Defendant shot at a car in which Reeves was a passenger. One of the bullets struck Reeves in the head, and he died. Defendant was convicted of murder, and he appealed.

     

    Issue.

    Whether a criminal defendant may be guilty of murder when his unlawful conduct was not directed at a specific victim, but manifested an extreme indifference to human life generally.

     

     

    Held.

    Yes. Defendant’s conviction is affirmed. Criminal homicide constitutes murder when it is committed recklessly and in a manner that manifests extreme indifference to human life.

     

    Discussion.

    Murder is the unlawful killing of another with malice aforethought. Malice aforethought includes extreme indifference to human life. Unlike purposeful or knowing murder, reckless murder manifesting extreme indifference to human life—also known as “depraved heart murder”—does not require evidence that the defendant intended to kill or seriously injure a particular victim. Instead, guilt for reckless murder turns on the whether the defendant’s actions manifested an extreme indifference to human life in general. A defendant’s conduct is reckless when it is taken with awareness and conscious disregard of a substantial and unjustifiable risk. What constitutes “extreme indifference” to human life varies from case to case, but requires some showing of conduct that is shocDefendant, outrageous, or especially heinous. Here, the evidence adduced at trial demonstrated that Defendant was aware that shooting at the car posed a substantial and unjustifiable risk of death to the passengers of the car and anyone else on the highway at that time. The evidence also demonstrated that Defendant consciously disregarded this risk, and that his conduct manifested an extreme indifference to human life generally.

     


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