Closed Book, 3 Hour Essay
- Exam Information:
- Closed Book, 3 hour essay
- Possibly essay w/ sub-parts
- Hypothetically: develop the case/example
- MPC provisions will not be on exam itself
- Be prepared for other statute to work into CL analysis or MPC analysis
- Be prepared to address mental state requirement
- Contrast CL with MPC
- CL w/ statutory variations
- Note major differences between CL and MPC
- Ex: statutes that modify CL murder
- First: state here is what CL said as to murder (3 types)
- express malice
- felony murder
- depraved hear murder
- State statutes often divide murder into 1st and 2nd degree
- 1st: premeditated and deliberate
- 2nd: ….
- If not given a statute just mention the above in passing (don’t dwell on it): good discussion of CL rules will be almost as many points even if fail to mention this statutory stuff
- Ex: Attempt
- Some CL has been codified
- Ability to analogize to relevant case-law
- Ex: this is like case where Defendant consumed quart of wine and LSD and court found this was relevant b/c….
- Policy
- Renunciation, withdrawal, unilateral conspiracy
- Why law does or does not recognize these things
- Policy considerations in the particular circumstances
- Example Exam Question:
- I. “…..”
- Questions:
- 1(a)……
- 1(b)……
- 1(c)……
- Answer the question according to question as numbered
- Essay answer: not just (1) Yes or No and (2) why Yes or No
- Instead:
- plausible approach to question
- start w/ definition
- mention strengths
- then branch off
- Thread of Analysis through appropriate crimes
- apply facts to these elements of crimes
- Supplement: Criminal Law (by LaFave)
- Look to clarify understanding (Table of Contents)
- See relationship of principles
- Elements of a doctrine
- Introduction
- Contrast between Criminal and Civil Law
- Criminal Prosecution: intervene because conduct presents public danger
- Burden of Proof:Criminal: beyond a reasonable doubt
- Act + Intent + Causation = Liability
- Model Penal Code: promulgated by ALI
- Will be contrasted w/ Common Law throughout semester
- Imputability
- The Necessity of an Act
- Crime requires either a voluntary physical act or an omission when there is a legal duty to act
- Palmer v. City of Euclid
- Facts: Palmer dropped female friend off at apt.
- Held: statute was void for vagueness as applied to Mr. Palmer
- Act: necessary element to form a crime
- What Constitutes an Act
- Voluntary Act: Defendant must have committed voluntary act (subject to a few exceptions): Voluntary Act = “Actus Reus”
- Reflex or Convulsion – an act consisting of a reflex or convulsion does not give rise to criminal liability
- State v. Taft
- Facts: emergency brake released, charged w/ D.U.I.
- Held: the mere movement of a vehicle does not necessarily in every circumstance constitute a “driving” of the vehicle
- Voluntary Act: in course of conduct under MPC
- Possession: power + intent to control (conscious possession)
- MPC Possession: In situation: aware of control and for sufficient period of time to terminate her possession
- People v. Decina
- Facts: Defendant subject to epileptic attacks and suffered attack, vehicle jumped curb and killed 4 people
- Held: once Decina began to operate the vehicle that is when the act occurred.
- Conscious risk-taking: Negligence in this case: operating the vehicle…
- State v. KimbrellPossession
- Facts: Charged w/ trafficking cocaine (based on possession of the cocaine), cocaine remained on table while husband was to make the drug deal
- Possession: power + intent to control (disposition)
- Ex: could have thrown it away while husband gone
- If possession = element of crime generally construed to be conscious possession
- Negative Acts/Ommission
- In some cases: omission may be basis for criminal liability
- Legal Duty:(essentially when defendant has a duty to act imposed by civil law)
- Relationship
- Statute
- Contract (express or implied)
- Voluntary assumption of care: usually if person isolated (?)
- Creation of peril
- Biddle v. Commonwealth (CB 492)
- Facts: severely malnourished infant, failure to feed infant
- Criminal omission would be based on duty of status relationship between parent and child (Failure to fulfill duty = culpable omission)
- Failure to feed child
- Commonwealth v. Teixera
- Facts: nonsupport for illegitimate child
- Omission: nonsupport
- Legal Duty: statute gave duty to support children
- Duty to act
- Must be legal duty and not just moral duty
- Absent statute requiring Good Samaritan rescue: may have breached a moral duty but not a legal duty
- Jones v. U.S.
- Facts: child neglect, 2 defendants: Green (mother) and Jones (caretaker)
- Who has duty?
- Green: parental status
- Jones: contract or voluntary assumption
- Held: trial court failed to instruct that jury must find a breach of a legal duty
- Davis v. Commonwealth
- Facts: mother froze to death or starvation, room where daughter staying had evidence of person living there
- Held: implied contract b/c defendant derived economic benefits (food stamps, welfare, live free in mother’s home)
- Van Buskirk v. State
- Argument, boyfriend ordered out of car, girlfriend struck him, she left, boyfriend hit later by a different car
- If Van Buskirk created the peril: her failure to reasonably alleviate the peril would be a culpable omission
- Responsibility/Mental State
- Mens Rea
- Concurrence: act and intent
- Must have an act in addition b/c guilty mind alone cannot constitute a criminal offense
- Defendant’s conduct (actus reus) often is primary evidence in proving the defendant’s mental state
- requirement that there be a “culpable state of mind”; intent; knowledge (“guilty mind”)
- Exceptions: Some crimes are defined in such a way that the “mens rea” is merely negligence or recklessness
- Criminal Negligence/Recklessness: substantial deviation from the standard established by law
- Criminal Negligence: inadvertent risk-taking
- Defendant should be aware of risk
- reasonable person would have realized the risk (Ex: Gian-Cursio)
- Recklessness: conscious risk taking, a gross deviation (Ex: Petersen)
- Recklessness:
- Aware of risk
- Consciously disregards
- Substantial and unjustifiable risk
- Elements leading to finding of criminal recklessness:
- if degree of risk great enough
- risk substantial
- defendant aware
- MPC requires that there be a conscious disregard of a known risk for an act to be reckless
- Objective Standard v. Subjective Standard:
- Objective standard – “reasonable person” (i.e what should he have done)
- Subjective standard – done in good faith (i.e. intent)
- Gian-Cursio v. State: criminal negligence
- Facts: Chiropractor treated TB w/ fasting, Mozian died as result
- Difference between medical malpractice and manslaughter: gross incompetence then may rise to level of criminal negligence
- State v. Petersen: Recklessness
- Facts: Drag race, Petersen stopped at intersection, Wille continues, hits truck and dies along w/ passenger, Warren
- Held: Petersen took unjustified, huge risk (gross deviation)
- Reckless act: setting the race in motion
- Risk he created continued up to and including the time of the collision
- Petersen helped set in motion this force (the other driver)
- State v. Howard: intent, recklessness, negligence
- Facts: shot guy getting in the way of him protecting his friend, then shot the guy
- Held: No reasonable basis under facts to justify negligent homicide
- Howard was acting intentionally: explained by his raising self-defense (intended serious bodily injury/kill)
- Explanation of manslaughter conviction (lower charge to manslaughter:
- imperfect self-defense:
- if defendant had unreasonable belief
- or if reasonable belief: did not justify “deadly force”
- Specific Intent
- General Intent: D desired to commit the act which served as the actus reus
- Given intent to do actus reus, the intent to do all things that are natural and probable result of the act may be presumed
- Specific Intent: D, in addition to desiring to bring about the actus reus, must have desired to do something further
- For these offense: neither negligence nor the intent to do a different crime is sufficient (Ex: burglary)
- Thacker v. Commonwealth
- 3 drunk men, “shoot lights out” of tent, fired shots that went through Mrs. Ratrie’s bed
- Specific Intent: mental state needed for attempted murder = intent to kill (not specific intent to do some other act, i.e. “shoot the lights out”)
- Other Particular States of Mind
- Malice
- Malice: implies intent to do wrong
- intent to annoy, vex or injure another
- intent to do wrongful act
- State v. Nastoff
- Facts: modified chain-saw emitted carbon, smoldered and caused fire
- Held: Nastoff didn’t intend to do the wrongful act the statute describes: intent to injure property (the malice the statute describes)
- Knowledge (Scienter)
- Knowledge
- Majority view: have actual knowledge (subjectively know)
- Minority view: objective: the defendant should have known
- MPC: A person acts knowingly under the MPC w/r/t the nature of his conduct or the surrounding circumstances, if he is “aware” that his conduct is of a certain kind or that certain circumstances exist; aware that it is practically certain that his conduct will cause that result
- Willful blindness/deliberate ignorance at CL
- MPC: if person is aware of a high probability of its existencethat can be a substitute for knowledge
- State v. BealeKnowledge: Subjective Test
- Facts: antique store, customer believes items are stolen, goods put back on display and sold
- Held: D himself must have believed that the goods were stolen i.e. subjective test: Subjective → believed → culpability
- U.S. v. JewellWillful Blindness
- Tijuana, “Ray” offers marijuana then offers $100 to drive car across the border, defendant looks around car and sees nothing
- Even if found that defendant did not know subjectively then willful blindness can serve as a proxy for knowledge
- Willful blindness here:
- Aware of high probability that there was marijuana in car (MPC)
- Deliberate ignorance: Jewell didn’t want to know the truth b/c of the consequences (CL)
- Willfulness
- Willful: intentional or purposeful
- Fields v. U.S.Willful
- Facts: didn’t produce 3 documents for House investigation committee
- Willful in this context does not mean evil purpose
- Willful: (here) more like deliberate purpose
- Strict Liability
- “malum in se”: evil in itself → mens rea
- Act + mental state
- Recognized as bad partly b/c of actor’s state of mind
- “malum prohitbitum”: statute criminalizes, no mental state necessary, can impose strict liability (not inherently bad: legis. authority makes act criminal)
- Accused’s good faith or innocent mistake is not a defense: liability depends solely upon commission of the prohibited act
- Commonwealth v. OlshefskiStrict Liability
- Facts: overweight truck, weigh bill
- With this type of statute: does not matter that Olshefski did everything in his power to obey the law
- Unlawful Conduct
- General Intent: volitionally doing a prohibited act
- intent to commit the act which constitutes the crime
- Transferred Intent
- Elements:
- If contemplated harm was criminal
- And there is great similarity between that harm and the actual result
- Then: the actor may be held criminally liable for the actual result
- Gladden v. State: Transferred Intent
- Facts: Bad heroin deal, Gladden shot wildly at Siegel, hit 12 years old boy who died
- Theory of case: not that Gladden was reckless but this is intentional murder
- “intention follows the bullet”
- Cuellar v. State: Who qualifies as “another”
- Facts: fetus, car accident, baby born alive (emergency c-section) then died 43 hrs. later from injuries
- analogous to CL rule: baby must be born or in process of being born
- Offenses Against the Person (Homicide)
- Homicide: What mental states will suffice?
- Murder
- Common Law: malice aforethought, intent to kill or injure
- Malice aforethought (express or implied)
- express:
- Intent-to-kill
- Intent to commit grievous bodily injury
- implied:
- felony-murder rule: commission of underlying felony: presumption of malice
- depraved heart murder: so extremely reckless or indifferent to value of human life generally that malice is implied
- Depraved Heart Murder (reckless indifference)
- universal malice, not directed at any one person
- Depraved Heart Murder Elements:
- know risk but disregard
- unjustifiable risk to human life
- no social utility
- King v. State
- Facts: followed out of nightclub, then shot at tires of vehicle
- Reckless → extreme indifference → life generally
- High degree of risk: death
- Awareness of risk: consciously disregard it
- Awareness of Risk: Actual Risk v. Probability (Subjective standard: awareness of risk)
- Ex #1: walking down suburban street, shoots out windows of home, hits occupant: Jury will find: person aware of risk
- Ex #2: walking in forest, cabin appears abandoned, shoot out windows, there was occupant who was killed: Harder case
- Conduct = gross deviation from the standard of care a reasonable person would exercise
- Consider the possible social utility: if justifiable for taking the high degree of risk
- substantiality of the risk: likelihood / probability that it will cause harm, but the higher the justification for the conduct you can have a lower degree of risk.
- State v. HokensonPart of continuous transaction: criminally liable
- Facts: D calls in prescription, enters w/ bomb and knife, was under arrest, bomb went off in officer’s hands
- We are presuming recklessness for what period of time?
- Responsible for the forces set in motion by your recklessness→ continuous transaction
- Until the forces are not in motion anymore: you will be strictly liable
- Felony-Murder
- Felony-Murder Elements:
- unintended killing
- underlying felony: no mens rea for murder but need it for underlying felony
- Inherently dangerous felony
- Presumption of Malice: b/c underlying felony is inherently dangerous
- Inherently Dangerous Felony Test:
- Must look at the felony in the abstract
- Must show: high probability of risk of death (more than 50%)
- Natural and probable consequence (Ex: Patterson below: is death natural and probable consequence of furnishing cocaine?)
- People v. Phillips: Inherently Dangerous Felony (abstract)
- Facts: chiropractor treating 8 year old for cancer
- Held: No felony-murder applied here b/c not an inherently dangerous felony
- Here: person could commit fraud (medical fraud) w/o ever causing a serious risk that someone would die
- People v. Patterson: Inherently Dangerous Felony Issue
- Facts: Defendant supplied cocaine, Jennie Licerio died
- Held: case remanded to determine if felony of furnishing cocaine = inherently dangerous
- Problem: Felony-Murder Rule divorces responsibility element from the culpability element (Presumes malice)
- If criminal liability rests on moral culpability: then isolate F-M rule as much as possible
- State v. MayleWhen does felony end?
- Facts: attempted robbery at McDonald’s in Ohio
- Held: felony still occurring when the officer was shot
- F-M rule includes: things immediate and that immediately follow the commission/attempt of the felony
- Complete and continuous transaction until they reach a place of safety
- People v. WilsonMerger Principle
- Facts: killing of Mrs. Wilson in the bathroom
- Court concerned: losing distinctions between different types of murders: Assault w/ deadly weapon merging into homicide
- Ex:Voluntary MS always a felony and if it is allowed as a predicate for F-M then voluntary MS will always get bootstrapped up to murder
- People v. HansenMerger Principle: Assaultive Conduct
- Facts: clearly reckless conduct (if he would have known the kids were inside he would not have shot)
- Shooting into occupied building: Assaultive conduct (felony)
- Held: doesn’t merge into homicide
- California stance on F-M rule:
- Merger Principle:If all you have in the box is “assault”: not enough for F-M
- Human Shield Cases: Clearly a case of murder as it is a reckless act with extreme indifference to human life.
- Premeditation/Deliberate Murder
- Elements: (measuring cold calculated judgment v. impulse)
- Willful → intentional
- Deliberate → thought
- Cool mind that is capable of reflection
- Premeditated → beforehand
- Actual reflection beforehand
- People v. PerezPlanning/Motive/Manner
- Facts: victim stabbed 38 times, D went to same H.S.
- Typical premeditation categories:
- Planning
- Motive
- Manner
- Held: sufficient evidence to support jury’s finding of premeditated/deliberate murder
- Length of time to form: does not have to be long
- Just: cool reflection showing conscious decision to kill victim (rule out impulse)
- Provocation: Something considered provocation can negate the cool deliberation needed for premeditation
- 2nd degree murder: can include intentional killing
- 1st degree murder: must add cool mind and actual reflection
- State v. SchraderNo appreciable time required to form intent to kill
- Facts: D to purchase war souvenirs, argument over authenticity of German sword
- Deliberate/premeditated: held to be knowing and intentional
- Midgett v. StateHomicide must be premeditated/deliberate
- Facts: Father hit malnourished child in stomach and killed him
- Held: Father intended abuse but had no intent to kill
- Ex: if D thought for a long time planned to kill boy and then got drunk to get up courage
- Court likely to find: premeditation and deliberation
- State v. ForrestMoral Justification not Adequate to reduce charges
- Facts: D kills father, terminally ill in hospital
- D admitted intended this (put father out of misery)
- Elements:Armed, D’s statement, Multiple shots (cocked pistol), No provocation, Helpless victim
- Use Elements to determine:If cool mind and Deliberate act
- Statutory Homicide
- 1st Degree
- premeditated and deliberate
- Some jurisdictions: focus on the method/means, may include F-M
- 2nd Degree
- include all other murders:go back to Common Law: every C.L. murder not in 1st degree category falls in this catch-all category
- MPC Murder (CB 216)
- Purposely/knowingly: similar to Common Law Express Murder
- Felony Murder: similar to Common Law (presumption of malice)
- enumerated felonies (MPC 210.2(1)(b))
- Recklessly: extreme indifference to value of human life: similar to C.L. depraved heart
- Voluntary Manslaughter
- Voluntary Manslaughter Policy Issues:
- Recognize human frailty: people sometimes act out of heat of passion
- Search for rule that mitigates culpability
- Common Law
- Intentional killing of another human being
- Heat of Passion:extreme emotional state
- sudden
- subjective test: did D lose control?
- Adequate Provocation
- legal adequacy: defined in rigid CL categories
- Defendant acts in response to a provocation that a reasonable person would lose self-control (objective inquiry)