State v. Lauglin

Brief Fact Summary.

Defendant appeals a conviction of feloniously, willfully, and maliciously setting fire to a barn.

Synopsis of Rule of Law.

A defendant who commits an illegal act may be found guilty for any subsequent criminal act, which is the natural and probable consequence of committing the first illegal act.

Facts.

Lauglin (Defendant) intentionally set fire to a stable and the fire spread to a nearby barn, which contained corn and peas. Although the barn was burnt, it was not completely destroyed. Defendant was indicted for “feloniously, willfully, and maliciously” setting fire to the barn. Defendant was convicted and he appealed.

Issue.

Whether a defendant who commits an illegal act may be found guilty for any subsequent criminal act, which is the natural and probable consequence of committing the first illegal act.

Held.

Yes. Defendant’s conviction is reversed on other grounds. A defendant who commits an illegal act may be found guilty for any subsequent criminal act, which is the natural and probable consequence of committing the first illegal act.

Discussion.

Defendant argues on appeal that he cannot be convicted of “willfully” setting fire to the barn because that was not his original intent. The trial court correctly found that Defendant is responsible for any natural and probable consequence resulting from his first criminal act. Setting fire to a house or stable, by itself, is a high misdemeanor. But if there are persons inside the house who become injured by the fire, the crime is elevate to a felony and the defendant is responsible for their injuries as a result of the natural and probable consequences doctrine.