United States v. Carter

Brief Fact Summary. Defendant was with another individual when they got into a taxi cab, robbed the driver and subsequently, the driver was killed. Defendant contends that he was not sufficiently involved in the commission of the murder.

Synopsis of Rule of Law. Defendant’s participation in the robbery was sufficient to support a charge of felony murder, even if the murder was not contemplated by Defendant.

Facts. Defendant and another were picked up by a local taxi cab. The other individual told the driver to stop, when he did not immediately do so, the driver was shot and killed. Defendant and another were charged with robbery, premeditated murder, and felony murder. The jury convicted on robbery and felony murder grounds, but Defendant was acquitted of premeditated murder.

Issue. Whether there was sufficient evidence to convict the Defendant of felony murder.

Held. Both convictions are affirmed.
Defendant if involved in the commission of the robbery was also guilty of felony murder.

Defendant’s participation in the robbery that resulted in a killing, even if the killing was not remotely in Defendant’s mind, is sufficient to support a conviction for felony murder.

Dissent. The dissent disagreed with the felony murder conviction and concurred with the affirmed robbery conviction. The dissent believed that the killing of the cab driver was an independent act of the other man and did not involve Defendant.

Discussion. The Court weighed both the testimony of the Government’s witnesses as well as that of Defendant. The key testimony came from Defendant himself when he testified that he was holding the cab driver and thus he did not think that the other individual would have to kill the cab driver. The fact that Defendant was involved in the robbery was sufficient to support a conviction for felony murder.