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Criminal Law Keyed to Johnson
People v. Whitfield
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*Case Brief Anatomy includes: Brief Prologue, Complete Case Brief, Brief Epilogue
- The Brief Prologue provides necessary case brief introductory information and includes:
- Topic: Identifies the topic of law and where this case fits within your course outline.
- Parties: Identifies the cast of characters involved in the case.
- Procedural Posture & History: Shares the case history with how lower courts have ruled on the matter.
- Case Key Terms, Acts, Doctrines, etc.: A case specific Legal Term Dictionary.
- Case Doctrines, Acts, Statutes, Amendments and Treatises: Identifies and Defines Legal Authority used in this case.
- The Case Brief is the complete case summarized and authored in the traditional Law School I.R.A.C. format. The Pro case brief includes:
- Brief Facts: A Synopsis of the Facts of the case.
- Rule of Law: Identifies the Legal Principle the Court used in deciding the case.
- Facts: What are the factual circumstances that gave rise to the civil or criminal case? What is the relationship of the Parties that are involved in the case. Review the Facts of this case here:
Whitfield (Defendant), who had a prior record of drunk-driving offenses, collided with another vehicle, killing the driver. Defendant was found unconscious in his vehicle, with empty cans of liquor. Evidence indicated that Defendant may have passed out just before the accident. At trial, Defendant attempted to prove that he did not act with implied malice aforethought, because he was so intoxicated that he was unconscious at the time of the accident. The trial court instructed the jury that: (1) voluntary intoxication could be considered in determining whether Defendant had specific intent; (2) every person who unlawfully kills another with malice aforethought is guilty of murder; and (3) malice may be express or implied, and (4) malice is implied when: (a) the killing resulted from an intentional act; (b) the natural consequences of the act are dangerous to life; and (c) the act was purposely performed with conscious disregard for life. The court distinguished between implied malice and gross negligence, the required mental state for the lesser offense of gross vehicular manslaughter. The trial court refused Defendant’s requested jury instruction that “[i]f you find that a defendant, while unconscious as a result of voluntary intoxication, killed another human being without intent to kill and without malice aforethought, the crime is involuntary manslaughter.” The jury found Defendant guilty of second-degree murder. Defendant appealed, arguing that the trial court erred in refusing his jury instruction. In reviewing the case, the court of appeals held that evidence of voluntary intoxication cannot be introduced to negate implied malice, because second-degree murder based on implied malice is not a specific-intent crime.
- Issue(s): Lists the Questions of Law that are raised by the Facts of the case.
- Holding: Shares the Court's answer to the legal questions raised in the issue.
- Concurring / Dissenting Opinions: Includes valuable concurring or dissenting opinions and their key points.
- Reasoning and Analysis: Identifies the chain of argument(s) which led the judges to rule as they did.
- The Brief Prologue closes the case brief with important forward-looking discussion and includes:
- Policy: Identifies the Policy if any that has been established by the case.
- Court Direction: Shares where the Court went from here for this case.