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Keywords

defendantfelony

defendantappealwillfelonydue process

Related Cases

People v. Dillon, 34 Cal.3d 441, 668 P.2d 697, 194 Cal.Rptr. 390

Facts

Defendant, a 17-year-old high school student, conspired with friends to rob a marijuana farm after learning it was guarded. They armed themselves and planned the robbery, but when confronted by the farm's owner, Dennis Johnson, defendant shot him, resulting in Johnson's death. The group fled without taking any marijuana, leading to the charges against defendant.

At the time of these events defendant was a 17-year-old high school student living in the Santa Cruz Mountains not far from a small, secluded farm on which Dennis Johnson and his brother illegally grew marijuana. Told by a friend about the farm, defendant set out with two schoolmates to investigate it and to take some of the marijuana if possible.

Issue

Whether a standing crop can be the subject of robbery and whether the felony-murder rule can be judicially abrogated.

The case presents two principal issues. First, we inquire whether a standing crop can be the subject of robbery; declining to perpetuate an archaic distinction between that crime and larceny, we conclude that it can. We next address a multiple attack on the first degree felony-murder rule.

Rule

In California, the felony-murder rule is statutory and does not require proof of malice, and standing crops can be subject to robbery.

We also reject various constitutional challenges to the rule; we hold primarily that the rule does not deny due process of law by relieving the prosecution of the burden of proving malice, because malice is not an element of the crime of felony murder.

Analysis

The court found that the defendant's actions demonstrated a clear intent to commit robbery, as he and his companions armed themselves and planned the attack despite knowing the risks involved. The court ruled that the evidence was sufficient to support the conviction for attempted robbery, as the actions taken were direct steps towards committing the crime.

Here a rational trier of fact could have found that the evidence clearly demonstrated defendant's intent to rob. From their prior forays to the marijuana farm, defendant and his companions had learned that it was guarded by armed men who were able and willing to defend it by the use of deadly weapons if necessary.

Conclusion

The court affirmed the conviction but modified the sentence to second-degree murder, ruling that the life sentence for felony-murder was cruel and unusual punishment.

Because such disproportion is manifest on the record before us—as it was to the triers of fact—we modify the judgment to punish this defendant as a second degree murderer. As modified, the judgment will be affirmed.

Who won?

The People (State) prevailed in the case, as the court upheld the conviction for attempted robbery and felony-murder, but modified the sentence based on constitutional grounds.

Defendant appeals from a judgment convicting him of first degree felony murder and attempted robbery.

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