People v. Patterson

Brief Fact Summary.

Defendant was charged with felony murder when a woman died of acute cocaine intoxication after ingesting cocaine that Defendant furnished. The trial court dismissed the murder charge. The court of appeals affirmed. The prosecution appealed.

Synopsis of Rule of Law.

Felony murder is a homicide that is the direct causal result of the commission of a felony that is inherently dangerous to human life.

Facts.

On November 25, 1985, Mr. Patterson (Defendant) and two women ingested cocaine that Defendant had furnished to the group. One of the women, Jennie Licerio, died of acute cocaine intoxication. Defendant was charged with, among other things, felony murder. The prosecution argued that Defendant was guilty of felony murder because he committed an inherently dangerous felony by furnishing cocaine to Licerio. The trial court dismissed the murder charge, and the prosecution appealed. The court of appeals affirmed the dismissal. The prosecution petitioned the state supreme court for review.

Issue.

Whether a defendant may be guilty of felony murder when he furnishes cocaine to a person who dies as a result of ingesting the cocaine.

Held.

Yes. The court of appeals is directed to remand the case to the trial court. Felony murder is a homicide that is the direct causal result of the commission of a felony that is inherently dangerous to human life.

Discussion.

A felony is inherently dangerous to human life when there is a high probability that its commission will result in death. To determine whether the commission of a particular felony is inherently dangerous, courts examine the elements of the felony in the abstract, not the particular facts of the case. When analyzing the felony in the abstract, courts must only consider the particular crime at issue, not the entire scope of conduct that a statute prohibits. Here, the felony underlying Defendant’s felony murder charge was furnishing cocaine to the victim. The statute prohibiting this conduct included other drug offenses. The trial court and court of appeals erred when they analyzed the statute in its entirety to determine whether Defendant committed an inherently dangerous felony.