Northington v. State
1981 Ala. Crim. App. LEXIS 2503, 413 So.2d 1169 (1981)
Rule of Law:
Under Alabama law, the crime of reckless homicide manifesting extreme indifference to human life (universal malice) applies only when the defendant's conduct presents a grave risk to human life generally, and does not apply when the conduct is directed specifically at a particular individual.
Facts:
- The defendant was the mother of a five-month-old infant, Dana Northington.
- Over a period of time, the defendant withheld food from the infant.
- The defendant also withheld medical attention from the infant.
- The defendant's actions and omissions were directed specifically at her daughter and no other person.
- As a result of the starvation and lack of medical care, the infant died.
Procedural Posture:
- The State indicted the defendant on two counts: intentional killing (Count 2) and reckless homicide manifesting extreme indifference to human life (Count 1).
- At the trial court, the defense counsel moved to exclude Count 1 from the jury, arguing the statute did not apply to acts against a specific person.
- The trial court denied the motion and submitted Count 1 to the jury.
- The jury convicted the defendant of Count 1 (reckless homicide manifesting extreme indifference).
- The trial court sentenced the defendant to life imprisonment.
- The defendant appealed the conviction to the Alabama Court of Criminal Appeals.
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Issue:
Does the offense of reckless homicide manifesting extreme indifference to human life apply when the defendant's dangerous acts are directed solely toward a specific victim rather than the public generally?
Opinions:
Majority - The Court
No, the statute for reckless homicide manifesting extreme indifference to human life does not apply to acts directed at a single, specific victim. The court reasoned that this statutory offense, historically known as 'depraved heart' murder or 'universal malice,' is intended to cover situations where a defendant has no specific intent to kill a particular person but acts with gross recklessness toward human life in general. Examples include shooting into a crowd or throwing timber from a roof. The court cited precedents such as Napier v. State and State v. Berge to demonstrate that while the statute no longer requires more than one person to be endangered, it still requires that the indifference be displayed toward 'human life' in an abstract, general sense. Because the evidence showed the defendant's starvation of the child was conduct directed solely at a specific victim, it did not satisfy the legal elements of the crime charged in the indictment. Consequently, the evidence was insufficient to sustain the conviction under this specific statute.
Analysis:
This decision underscores the critical importance of prosecutorial precision in charging documents. The court distinguished between 'universal malice' (general recklessness toward the public) and acts directed at a specific individual. Although the defendant's conduct was heinous, the State failed to prove the specific legal elements of the crime charged (reckless indifference to human life generally). The court was forced to reverse the conviction because the facts—starvation of a specific child—contradicted the definition of the crime, which requires a non-specific risk to the public. This case serves as a precedent that 'depraved heart' murder cannot be used as a catch-all for specific-intent killings that prosecutors might find difficult to prove otherwise.
