Yes, the dealer is guilty of murder. The court explained that the drug deal and the deadly chase were all part of one single, continuous event. Even though the drug sale was technically finished, the chase and shooting happened immediately because the deal went wrong. Because the killing was a direct result of the drug crime, the dealer is responsible for the bystander's death.

The highest court agreed with the lower appeals court. They said letting in some wrong evidence about Yates confessing didn't matter because other witnesses said similar things without any objection. They also said Yates could be guilty of felony murder because the death and the drug crime were very closely related in time, place, and cause, even if the crime was technically over before the shooting. The court said this 'continuous transaction' idea applies for felony murder. Lastly, they said the appeals court didn't do anything wrong by not looking at the jury instructions again because the instructions followed the usual pattern and courts only fix really big obvious mistakes.

Where competent evidence of a matter is received, no prejudice is sustained where other objected to evidence of the same matter is also received

—" `will not find reversible error on appeal when objectionable testimony is admitted if the essential contents of that objectionable testimony have already been established and presented to the jury without objection through the prior testimony of other witnesses.'"

"Plain error review is reserved for errors that are `compelling, extraordinary, exceptional or fundamental to assure the defendant a fair trial.'"

We concluded that "the admission of the hearsay evidence did not ultimately affect the jury's verdict given the cumulative nature of the similar statements offered at trial."

A claim of error in the admission of evidence is "waived if, at another point during the trial, evidence on the same point is admitted without objection."

As for appellant's concern about the word "fiens," it appears that was waived because, as set forth in our background discussion, Trooper Stevens testified, without objection, to the meaning of fiends in the context of drug distribution.

—the Court of Appeals rejected the notion that once the elements of the predicate felony have been accomplished, a subsequent killing does not constitute a felony murder.

"[T] he felony murder doctrine applies when the felony and the homicide are parts of one continuous transaction and are closely related in point of time, place [,] and causal connection."

At the outset, we note that it is well-established that a trial court is strongly encouraged to use the pattern jury instructions.

Generally, where a party fails to object to a trial court's refusal to give a requested instruction, the issue is not preserved for appellate review.

Yes, the felony murder doctrine applies. A homicide committed after the core elements of a felony are complete can still be considered 'in the perpetration of' that felony if the two events are part of a single continuous transaction. The court's reasoning rests on the principle that a crime does not necessarily end the moment its technical elements are met but can extend to include immediate flight or acts taken to secure the fruits of the crime. Here, Yates's pursuit and shooting of Kohler were not a separate act of revenge but an immediate reaction to being duped in the drug deal. The chase and shooting were so closely connected in time, place, and causal relation to the distribution of marijuana that they formed one continuous criminal event, making Yates liable for the resulting death of Shirley Worcester under the second-degree felony murder doctrine.

The Court of Appeals affirmed the judgment of the Court of Special Appeals. First, the admission of hearsay evidence relaying Yates's alleged confession was harmless error because similar statements were admitted without objection through the testimony of other witnesses. Second, Yates's killing of Worcester constituted second-degree felony murder because the homicide and the underlying felony of marijuana distribution were part of a continuous transaction, closely related in time, place, and causal connection. The Court adopted this 'continuous transaction' theory, holding that a precise confluence in time between the killing and the predicate felony is not required. Finally, the Court of Special Appeals did not abuse its discretion in declining to conduct plain error review of the jury instruction on second-degree felony murder, as the instruction tracked the pattern jury instructions and plain error review is reserved for extraordinary errors.

Yates v. State

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