Brief Fact Summary.
Cavitt (Defendant) and Williams (Defendant) conspired with Mianta McKnight to break into her stepmother’s house and rob her. The stepmother died shortly after the Defendants left her tied up and face-down on the bed. Defendants were convicted of felony murder and appealed, arguing that Mianta killed her stepmother after they left.
Synopsis of Rule of Law.
A defendant can be convicted of felony murder when he did not commit the murder so long as there exists a logical nexus between the felony and the killingeven if the killing did not further the purpose of the felony.
Defendants conspired with Mianta McKnight to rob her 58 year-old stepmother, Betty McKnight. On December 1, 1995, Mianta helped Defendants to enter Betty’s home. The men put a sheet over Betty’s head and tied the sheet to her wrists and ankles with rope and duct tape. The men took jewelry and other valuables and left Betty tied up and face-down on the bed, having difficulty breathing. The Defendants pretended to tie up Mianta. Mianta untied herself and called her father to report the burglary, but by that time Betty had died from asphyxiation. At trial, Defendants admitted to the burglary-robbery, but claimed that Mianta suffocated Betty after they left for reasons unrelated to the burglary. Both Defendants were convicted of felony murder in separate trials and appealed.
In order for a defendant to be convicted of felony murder for a murder he did not commit, must the murder have furthered the purpose of the felony?
(Baxter, J.) No. A defendant can be convicted of felony murder when he did not commit the murder so long as there exists a logical nexus between the felony and the killing even if the killing did not further the purpose of the felony. The Defendants here argue that the jury should have been instructed that the felony-murder rule would not apply if Mianta killed her stepmother for reasons unrelated to the felony. In order for nonkillers to be found guilty of felony murder, Penal Code section 189 requires both a causal relationship and a temporal relationship between the killing and the underlying felony. The causal relationship is proved by demonstrating a logical nexus between the killing and the felony that is greater than a coincidence of time and place. The temporal relationship is proved by demonstrating that the underlying felony and the killing were one ongoing action. Defendants argue that in order to be found guilty of felony-murder as nonkillers, the State must have proved that Mianta intended to kill Betty to advance the underlying felony. The purpose of the felony-murder rule is to avoid considering a killer’s intent. In other jurisdictions, the felony-murder statutes require the killing to have occurred “in furtherance” of the felony, but do not require that the killing aid or further the felony. “In furtherance” of the felony does not mean that it was necessary to the success of the felony. Similarly, this court requires only that there exists a logical nexus between the killing and the felony. Here, the jury found the killing occurred during the burglary-robbery by persons engaged in its commission. These findings satisfy both the causal and temporal relationships necessary to find Defendants guilty of felony-murder. Affirmed.
The court here focused on the Defendants’ intent to commit the underlying felony and not on any intent to commit the killing. The offenses listed in Penal Code 189 as qualifying underlying felonies are only those that are inherently dangerous or violent. Intent to commit these felonies is enough to put an offender on notice that death could result. Therefore, a death resulting from those felonies is first-degree murder regardless of the circumstances and even if the co-actor does not actually participate in the killing.