The People v. Jonathan Earl Stamp et al.
2 Cal.App.3d 203 (1969)
Rule of Law:
Under the felony-murder rule, a defendant is strictly liable for any death that is a direct causal result of the commission of a felony, regardless of whether the death was foreseeable or if the victim had a pre-existing medical condition that made them particularly vulnerable.
Facts:
- Carl Honeyman, a 60-year-old man, was the owner and manager of the General Amusement Company.
- Honeyman had a pre-existing and advanced case of heart disease (atherosclerosis) and was under significant business-related stress.
- Jonathan Stamp and Michael Koory, armed with a gun and a blackjack, entered Honeyman's business to commit a robbery, while Billy Dean Lehman waited outside as the getaway driver.
- Stamp grabbed Honeyman by the elbow, propelled him from his office, and forced him and his employees to lie on the floor.
- The robbery lasted for approximately 10 to 15 minutes.
- Immediately after the robbers left, Honeyman appeared pale, had trouble breathing, and complained of his heart pounding.
- About 15 to 20 minutes after the robbery, Honeyman collapsed.
- Honeyman was pronounced dead on arrival at the hospital, with the coroner listing the cause of death as a heart attack, which medical experts testified was precipitated by the fright from the robbery.
Procedural Posture:
- Jonathan Earl Stamp, Michael John Koory, and Billy Dean Lehman were charged with robbery and murder in a California trial court.
- Following a trial, a jury returned verdicts of guilty of first-degree robbery and first-degree murder for all three defendants.
- The trial court sentenced each defendant to life in prison on the murder count.
- The defendants (appellants) appealed their convictions to the California Court of Appeal.
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Issue:
Does the felony-murder rule apply to hold defendants liable for first-degree murder when the fright and stress of a robbery directly cause a victim to suffer a fatal heart attack, even if the victim had a pre-existing heart condition and the death was not reasonably foreseeable?
Opinions:
Majority - Cobey, Acting P. J.
Yes. The felony-murder rule applies to hold defendants liable for a victim's fatal heart attack caused by a robbery, even if the death was unforeseeable due to a pre-existing condition. The court reasoned that under California's felony-murder statute (Penal Code § 189), any killing committed during the perpetration of a robbery is murder of the first degree, regardless of intent. The doctrine presumes malice from the commission of an inherently dangerous felony. The court held that foreseeability is not a required element; rather, the felon is held strictly liable for all killings that are a direct causal result of the felony. A victim's predisposing physical condition does not absolve the defendant of responsibility as long as the felony was a substantial factor in causing the death. The court concluded that, in this respect, a robber takes his victim as he finds him.
Analysis:
This decision solidifies a strict and broad application of the felony-murder rule in California. By explicitly rejecting foreseeability as a necessary element for causation, the court affirmed that 'but-for' causation is sufficient. This case firmly imports the tort principle that one 'takes his victim as he finds him' into criminal homicide law, creating strict liability for the physical frailties of a victim. This precedent significantly limits the ability of defendants in similar cases to argue that a victim's pre-existing condition constitutes an intervening cause that breaks the chain of causation.
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