King v. State
505 So.2d 403 (1987)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
Intentionally firing a weapon at an occupied vehicle on a public highway is an act that manifests an extreme indifference to human life generally, sufficient to support a conviction for reckless murder under a 'depraved heart' theory.
Facts:
- Christopher Doyle King and Dwight Lee Reeves had a verbal altercation after bumping into each other at a nightclub.
- After leaving the club, King, driving his truck with his friend Bobby Knight, spotted Reeves in a car on the interstate being driven by his cousin, Rodney Dunnaway.
- King recognized Reeves and proceeded to tailgate Dunnaway's vehicle for several miles while blinking his truck's lights.
- King told Knight he was going to "mess with them and shoot the tires out."
- King then pulled his truck alongside Dunnaway's car and fired a .38-caliber pistol two or three times at the vehicle.
- One bullet pierced the passenger-side window and struck Reeves in the head, causing his death several hours later.
- Reeves and Dunnaway were unarmed and did not provoke the shooting.
- After the shooting, King disposed of the pistol in a dumpster.
Procedural Posture:
- Christopher Doyle King was indicted by a grand jury on two counts of murder.
- The case was tried before a jury in a state trial court.
- The jury found King guilty of one count of reckless murder manifesting extreme indifference to human life.
- The trial court sentenced King to twenty years' imprisonment and a fine.
- King filed a motion for judgment of acquittal at the close of the state's case and a motion for a new trial after the verdict; the trial court overruled both motions.
- King (appellant) appealed the judgment to the Court of Criminal Appeals of Alabama, arguing that the State (appellee) presented insufficient evidence to support the conviction.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does intentionally firing a pistol at an occupied vehicle on a public highway constitute reckless murder by manifesting an extreme indifference to human life generally under Alabama Code § 13A-6-2(a)(2)?
Opinions:
Majority - Patterson, J.
Yes. Intentionally firing a pistol at an occupied vehicle on a public highway constitutes reckless murder by manifesting an extreme indifference to human life generally. The court reasoned that the 'extreme indifference to human life' element, central to depraved heart murder, addresses conduct that creates a grave risk to human life generally, not just to a specific victim. This doctrine is intended for acts like shooting into a crowd, a moving train, or, as in this case, an occupied automobile. The court found that King's conduct of firing a weapon at a moving vehicle on a public interstate created a grave risk of death not only to the intended target, Reeves, but also to the driver, Dunnaway, and any other person who might have been using that highway. This behavior demonstrated a 'don't give a damn attitude' and a total disregard for public safety, which is sufficient to meet the statutory standard for reckless murder.
Analysis:
This case clarifies that an act directed at a specific vehicle or individual can still satisfy the 'universal malice' or 'extreme indifference to human life generally' standard for depraved heart murder. The decision establishes that the focus is on the nature of the act itself and the grave, generalized risk it creates for everyone in the vicinity, not just the primary target. This precedent prevents defendants from arguing that their conduct was too targeted to qualify for this type of murder charge, thereby broadening the application of the statute to encompass acts like road rage shootings that endanger the public at large.
Unlock the full brief for King v. State