People v. Henderson
14 N.Y.S.3d 770, 35 N.E.3d 840, 25 N.Y.3d 534 (2015)
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Rule of Law:
A conviction for felony murder may be predicated upon the felony of burglary where the defendant's intent at the time of unlawfully entering a dwelling was to commit an assault against the victim who is ultimately killed.
Facts:
- William Henderson and two others, believing they had been robbed of drugs and money, broke down the door to an apartment to confront the suspected robbers.
- The apartment was occupied not by the suspects, but by the victim and his girlfriend.
- Upon entry, Henderson began screaming and then engaged in a fistfight with the victim.
- After the initial altercation, Henderson's group fled, but Henderson went to a nearby associate's apartment, grabbed a kitchen knife, stated he was "going to kill him," and returned to the victim's apartment.
- Henderson re-entered the apartment and, during a second fight, stabbed the victim in the back, causing a fatal wound to his aorta.
- In a statement from a prior trial, Henderson admitted he returned with the knife not to kill the victim, but because he was mad and wanted to "hurt him" and "even the odds."
Procedural Posture:
- William Henderson was convicted at a first trial of manslaughter and other charges but was acquitted of intentional murder.
- On appeal by Henderson, the Appellate Division reversed the judgment and ordered a new trial due to an error in dismissing a sworn juror.
- Henderson was subsequently re-indicted, and the new indictment was consolidated with the original for a second trial in County Court.
- At the second trial, a jury convicted Henderson of felony murder, first-degree manslaughter, and multiple burglary and assault charges.
- Henderson, as appellant, appealed to the Appellate Division, Third Department, which affirmed the conviction, rejecting his argument that the felony murder conviction was based on legally insufficient evidence.
- A Judge of the New York Court of Appeals (the state's highest court) granted Henderson, as appellant, leave to appeal the Appellate Division's decision.
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Issue:
Is the evidence legally sufficient to support a felony murder conviction where the predicate felony is a burglary committed with the intent to assault the victim who was ultimately killed?
Opinions:
Majority - Abdus-Salaam, J.
Yes, the evidence is legally sufficient. A rational trier of fact could conclude that the defendant committed the crime of burglary when he entered the apartment with the intent to assault the victim, and during that burglary, he caused the victim's death. Citing 'People v Miller', the court reaffirmed that a felony murder conviction can be based on a burglary where the underlying intent is assault. The legislature's inclusion of burglary as a predicate felony recognizes the heightened danger to individuals within their homes. The defendant's own testimony provided evidence that his intent upon reentry was to assault, not kill, the victim. Furthermore, the killing occurred 'in furtherance of' the burglary because there was a clear 'logical nexus' between the unlawful entry to commit an assault and the resulting homicide; the death was not merely coincidental to the felony.
Analysis:
This decision reaffirms and clarifies the application of the felony murder rule in New York, particularly in cases where an assault inside a dwelling leads to death. It solidifies the precedent from 'People v Miller', holding that the merger doctrine does not prevent a burglary conviction from serving as the predicate for felony murder, even when the intent for the burglary was to commit the assault that resulted in the homicide. The court's broad interpretation of the "in furtherance of" requirement as a "logical nexus" test ensures that the felony murder statute continues to apply to a wide range of deaths that occur during the commission of a burglary, underscoring the legal system's policy of affording special protection to individuals inside their homes.
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