Case Name: People v. Burton
Citation: 491 P.2d 793 (1971)
Facts: Burton was committing the felony of armed robbery, during which he killed someone. He was arrested and charged with murder. At Trial, the Judge instructed the jury that they could find Burton guilty of first-degree murder if they found that the death happened as a result of the robbery, even if that death was unintentional.
State’s argument: The doctrine of felony-murder applies because armed robbery is inherently dangerous to life.
Defendant’s argument: An independent felonious purpose does not exist between the murder and the armed robbery.
Holding: An independent felonious purpose does exist and the defendant can be charged with felony-murder.
Reasoning: We look at the mind (mens rea) of the defendant committing the crime. The felony-murder doctrine is purposed to deter those committing felonies from killing people by holding them strictly liable for their deaths.