People v. Mattison
481 P.2d 193, 93 Cal. Rptr. 185, 4 Cal.3d 177 (1971)
Rule of Law:
A killing resulting from the administration of poison may constitute second-degree murder under the felony-murder rule when the underlying felony is willfully administering poison with intent to injure, even if the specific intent to kill required for first-degree murder is absent.
Facts:
- The defendant (Mattison) and the victim (Corcoron) were both inmates at the California Institution for Men, where the defendant worked as a technician in the medical laboratory.
- Corcoron, who had a history of alcoholism, sought to purchase alcohol from the defendant.
- The defendant supplied Corcoron with eight ounces of methyl alcohol, a substance kept in the laboratory and labeled as poison.
- Corcoron drank the mixture believing it to be consumable alcohol.
- Shortly after consuming the liquid, Corcoron became violently ill, his urine turned green, and he went blind.
- Corcoron died shortly thereafter, with the cause of death determined to be methyl alcohol poisoning.
- While the defendant knew the substance was poison, there was no evidence suggesting he entertained a specific intent to kill Corcoron.
Procedural Posture:
- The State charged Mattison with murder by information.
- A jury trial was held in the trial court.
- The trial court instructed the jury on first-degree murder, second-degree murder, felony murder, and involuntary manslaughter.
- The jury returned a verdict finding Mattison guilty of second-degree murder.
- Mattison appealed the judgment of conviction to the Supreme Court of California.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Is a conviction for second-degree murder legally permissible when a death results from the administration of poison, or does the statutory classification of murder by poison compel a verdict of either first-degree murder or acquittal?
Opinions:
Majority - Chief Justice Wright
Yes, a verdict of second-degree murder is proper because the use of poison does not automatically mandate a first-degree conviction if the specific malice required for first-degree murder is absent. The court reasoned that Penal Code section 189, which lists poison as a means of first-degree murder, only applies if the killing first qualifies as 'murder' with malice aforethought. In this case, the defendant lacked the specific intent to kill. However, the court applied the second-degree felony-murder rule. The defendant committed the felony of willfully administering poison with intent to injure (Penal Code § 347). The court determined this felony is inherently dangerous to human life and was committed with a 'collateral and independent felonious design' (to sell the substance/intoxicate) rather than solely to assault the victim. Therefore, the death resulting from this felony supports a second-degree murder conviction.
Analysis:
This decision is significant because it clarifies the application of the felony-murder rule in context with statutory enumerations of first-degree murder. The court resolved a potential legal paradox: while the statute explicitly lists poisoning as first-degree murder, applying that strictly would either force a jury to convict a defendant of first-degree murder for an accidental death (if they found malice) or acquit them entirely. By allowing second-degree felony murder, the court created a middle ground that punishes the dangerous conduct (poisoning) more severely than manslaughter but less severely than premeditated murder. This case also refined the 'Ireland' doctrine regarding 'integral' offenses, distinguishing cases where the underlying felony has a collateral purpose (like furnishing drugs/poison for consumption) from those where the felony is a direct assault.
