Criminal Law Keyed to Kaplan
State v. Martin
Facts
Defendant and four other individuals attended a party where all were consuming alcohol and using marijuana. After an altercation broke up the party, everyone left the building except for one woman, who had passed out from intoxication. On his way out of the building, Defendant set fire to a paper bag containing trash in order to “make a mess of things” but without intending harm to anyone. The building caught fire and the woman died from smoke inhalation. Defendant was tried for felony murder and convicted. He appealed, claiming that the court’s instruction to the jury that it did not matter whether the act which caused the death was committed recklessly, unintentionally, or accidentally was erroneous.
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