Mayes v. People
46 Am. Rep. 698 (1883)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
Malice, as an element of murder, may be implied when a defendant commits an act of general malicious recklessness that results in death, even without a specific intent to kill or injure the particular victim, if the circumstances show an abandoned and malignant heart.
Facts:
- Thomas Mayes, while intoxicated, was in a room with his wife, Kate Mayes, his daughter, and his mother-in-law.
- After a brief argument with his wife, Mayes became agitated, cursed, and stated that he would either kill his wife or she would kill him.
- Mayes then picked up and threw a tin quart measure at his daughter.
- Subsequently, as Kate Mayes was walking toward a bedroom with their daughter while holding a lit oil lamp, Thomas Mayes picked up a heavy beer glass.
- Mayes threw the beer glass with violence in the direction of his wife and daughter.
- The glass struck the lamp Kate Mayes was holding, breaking it and causing burning oil to spill onto her person, setting her clothes on fire.
- Mayes made no effort to extinguish the flames.
- Kate Mayes died from her severe burn injuries a few days later.
Procedural Posture:
- Thomas Mayes was charged by indictment with the murder of his wife, Kate Mayes.
- In the trial court, Mayes's motion to quash the indictment was denied.
- Following a trial, a jury found Mayes guilty of murder.
- The trial court entered a judgment of conviction and sentenced Mayes to life in the penitentiary.
- Mayes, as plaintiff in error, appealed his conviction to the Supreme Court of Illinois.
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 a defendant's act of throwing a dangerous object in the direction of others, without a specific intent to strike the victim, constitute murder if the act demonstrates an 'abandoned and malignant heart' and results in death?
Opinions:
Majority - Mr. Justice Scholfield
Yes. A defendant's act of throwing a dangerous object in the direction of others constitutes murder if it results in death and demonstrates an 'abandoned and malignant heart,' even without a specific intent to harm the victim. The court reasoned that malice is an essential element of murder but can be implied by law when no considerable provocation exists or when the circumstances of the killing show an 'abandoned and malignant heart.' Citing common law principles, the court explained that when an unlawful and deliberately mischievous action results in death, it is murder, regardless of the defendant's original intention. The act of violently throwing a heavy beer glass in the direction of his wife and child, especially after having just thrown a tin measure at his daughter, was an act of general malicious recklessness. It was immaterial whether Mayes specifically intended to strike his wife; his actions manifested a 'heart void of social duty, and fatally bent on mischief,' which is sufficient to imply the malice required for a murder conviction.
Analysis:
This decision solidifies the legal doctrine of implied malice, often referred to as 'depraved heart' murder, within Illinois law. It clarifies that the mental state for murder does not require a specific intent to kill or cause grievous bodily harm to the victim. The precedent allows for a murder conviction based on a defendant's extreme and reckless disregard for human life, where the act itself is so dangerous that malice can be inferred from it. This lowers the prosecution's burden in cases where a death results from an act of general recklessness rather than a targeted attack, influencing charging decisions and jury instructions in similar future cases.
