People v. Joyner
308 N.Y.S.2d 840, 26 N.Y.2d 106, 257 N.E.2d 26 (1970)
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Rule of Law:
For a conviction of felony murder, the intent to commit the underlying felony must be formed before or during the commission of the act that causes the victim's death. A killing does not constitute felony murder if the intent to commit the predicate felony arises only after the homicidal act has been completed.
Facts:
- The defendant told a friend he needed money and said, "I have to get it one way or another, even if I have to kill somebody."
- A few minutes later, the defendant approached Albert Hicks on the street.
- The defendant and Hicks entered a building together and emerged a short time later.
- Upon exiting the building, the defendant grabbed Hicks, turned him around, and stabbed him in the chest, causing a fatal wound to his heart.
- Hicks fell to the sidewalk, and the defendant was seen bending down and taking change from his pocket.
- When police arrived, they found Hicks' body on the sidewalk with one of his pants pockets turned inside out.
Procedural Posture:
- The defendant was tried in the Supreme Court, New York County, which is a trial-level court.
- A jury found the defendant guilty of felony murder.
- The defendant, as appellant, appealed the judgment to the Appellate Division, an intermediate appellate court.
- A divided Appellate Division reversed the defendant's conviction.
- The People (prosecution), as appellant, appealed the Appellate Division's reversal to the New York Court of Appeals, the state's highest court.
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Issue:
Did the trial court's jury instructions, including its response to a jury question about robbing a dead man, adequately convey the requirement that the intent to commit the predicate felony of robbery must be formed before or during the act causing death to sustain a felony murder conviction?
Opinions:
Majority - Chief Judge Fuld
Yes. The trial court’s instructions sufficiently informed the jury that the intent to rob must precede or co-exist with the act causing death. The court reasoned that to be guilty of felony murder, a defendant must kill 'in the attempted execution of the unlawful end,' meaning the intent to commit the felony cannot be an afterthought. Although the trial judge's response to the jury's question about robbing a dead man could have been clearer, it included the crucial phrases that the killing must be 'for the purpose of robbing him' and 'in the course of robbing him.' The court concluded that this language, combined with repeated instructions that the killing must occur 'during' the robbery, adequately conveyed the essential legal principle that the intent to rob could not be formed after the victim was killed.
Analysis:
This case reaffirms the critical temporal relationship between the defendant's mental state (mens rea) and the act (actus reus) in felony murder doctrine. It establishes that the intent to commit the underlying felony cannot be an afterthought to the killing. The court's decision also illustrates that appellate courts will review jury instructions as a whole; a single, potentially ambiguous statement may not constitute a reversible error if the overall charge correctly states the law. This ruling solidifies the distinction between a robbery that results in death (felony murder) and a killing followed by an opportunistic, separate act of larceny.
