felony-murder rule (West Virginia) · Go Syfert
← West Virginia issues

felony-murder rule in West Virginia

28 West Virginia opinions name it 1 courts 1977–2021 1 in the last five years

The cases below were cited by West Virginia courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (28)

CaseFollowedCited
People v. Aarongreen
mich · 1980 · cited in 3 West Virginia opinions naming this issue, 1983–2016
2 sentences

2016But see Garringer v. State, 909 P.2d 1142 , 1148–49 n.11 (Haw. 1996) (noting that Hawaii’s felony murder statute was repealed); Bennett v. Commonwealth, 978 S.W.2d 322, 327 (Ky. 1998) (“With the adoption of the penal code, the felony murder doctrine was abandoned as an independent basis for establishing an offense of homicide in Kentucky.”); People v. Aaron, 299 N.W.2d 304, 324 (Mich. 1980) (abolishing the common-law doctrine of felony murder).

2016But see Garringer v. State, 909 P.2d 1142 , 1148–49 n.11 (Haw. 1996) (noting that Hawaii’s felony murder statute was repealed); Bennett v. Commonwealth, 978 S.W.2d 322, 327 (Ky. 1998) (“With the adoption of the penal code, the felony murder doctrine was abandoned as an independent basis for establishing an offense of homicide in Kentucky.”); People v. Aaron, 299 N.W.2d 304, 324 (Mich. 1980) (abolishing the common-law doctrine of felony murder).

23
State v. Waynegreen
wva · 1982 · cited in 3 West Virginia opinions naming this issue, 1983–1997
2 sentences

1997On appeal, this Court found that the lower court “did not err ... by permitting the jury to consider the two robberies that occurred inside the penitentiary to invoke the felony-murder rule.” Wayne at 788 , 289 S.E.2d at 482 .

1985It is deemed sufficient if the homicide occurs accidentally during the commission of, or the attempt to commit, one of the enumerated felonies." This holding, however, has been reaffirmed in State v. Wayne, 289 S.E.2d 480, 482 (W.Va.1982); State v. Hatfield, 286 S.E.2d 402 , 408 n. 2 (W.Va.1982); State v. Taylor, 285 S.E.2d 635, 637 (W.Va.1981); and, Syl. pt. 8, State v. Grimmer, 162 W.Va. 588 , 251 S.E.2d 780 (1979), overruled on other grounds, State v. Petry, 273 S.E.2d 346, 352 (W.Va.1980), and, as we tersely noted in thinly disguised exasperation in State v. Taylor, 285 S.E.2d at 637: "Onc

23
State v. Taylorgreen
wva · 1981 · cited in 3 West Virginia opinions naming this issue, 1983–1991
2 sentences

1985It is deemed sufficient if the homicide occurs accidentally during the commission of, or the attempt to commit, one of the enumerated felonies." This holding, however, has been reaffirmed in State v. Wayne, 289 S.E.2d 480, 482 (W.Va.1982); State v. Hatfield, 286 S.E.2d 402 , 408 n. 2 (W.Va.1982); State v. Taylor, 285 S.E.2d 635, 637 (W.Va.1981); and, Syl. pt. 8, State v. Grimmer, 162 W.Va. 588 , 251 S.E.2d 780 (1979), overruled on other grounds, State v. Petry, 273 S.E.2d 346, 352 (W.Va.1980), and, as we tersely noted in thinly disguised exasperation in State v. Taylor, 285 S.E.2d at 637: "Onc

1985It is deemed sufficient if the homicide occurs accidentally during the commission of, or the attempt to commit, one of the enumerated felonies." This holding, however, has been reaffirmed in State v. Wayne, 289 S.E.2d 480, 482 (W.Va.1982); State v. Hatfield, 286 S.E.2d 402 , 408 n. 2 (W.Va.1982); State v. Taylor, 285 S.E.2d 635, 637 (W.Va.1981); and, Syl. pt. 8, State v. Grimmer, 162 W.Va. 588 , 251 S.E.2d 780 (1979), overruled on other grounds, State v. Petry, 273 S.E.2d 346, 352 (W.Va.1980), and, as we tersely noted in thinly disguised exasperation in State v. Taylor, 285 S.E.2d at 637: "Onc

23
Bennett v. Commonwealthgreen
ky · 1998 · cited in 2 West Virginia opinions naming this issue, 2015–2016
2 sentences

2016But see Garringer v. State, 909 P.2d 1142 , 1148–49 n.11 (Haw. 1996) (noting that Hawaii’s felony murder statute was repealed); Bennett v. Commonwealth, 978 S.W.2d 322, 327 (Ky. 1998) (“With the adoption of the penal code, the felony murder doctrine was abandoned as an independent basis for establishing an offense of homicide in Kentucky.”); People v. Aaron, 299 N.W.2d 304, 324 (Mich. 1980) (abolishing the common-law doctrine of felony murder).

2016But see Garringer v. State, 909 P.2d 1142 , 1148–49 n.11 (Haw. 1996) (noting that Hawaii’s felony murder statute was repealed); Bennett v. Commonwealth, 978 S.W.2d 322, 327 (Ky. 1998) (“With the adoption of the penal code, the felony murder doctrine was abandoned as an independent basis for establishing an offense of homicide in Kentucky.”); People v. Aaron, 299 N.W.2d 304, 324 (Mich. 1980) (abolishing the common-law doctrine of felony murder).

22
State v. Goodsealgreen
kan · 1976 · cited in 2 West Virginia opinions naming this issue, 1977–1978
2 sentences

1978See State v. Goodseal, 220 Kan. 487 , 553 P.2d 279 (1976); State v. Swift, 290 N.C. 383 , 226 S.E.2d 652 (1976); and Warren v. State, 29 Md.App. 560 , 350 A.2d 173 (Ct.Spec.App.1976).

1978See State v. Goodseal, 220 Kan. 487 , 553 P.2d 279 (1976); State v. Swift, 290 N.C. 383 , 226 S.E.2d 652 (1976); and Warren v. State, 29 Md.App. 560 , 350 A.2d 173 (Ct.Spec.App.1976).

22
State v. Simsgreen
wva · 1978 · cited in 6 West Virginia opinions naming this issue, 1979–2012
2 sentences

1986It is deemed sufficient if the homicide occurs accidentally during the commission of, or the attempt to commit, one of the enumerated felonies.” Specifically, this Court stated in Sims : The defendant’s trial counsel competently advised him as to the guilty plea, as there could be no reasonable expectation under the settled principles of our law that an unintended homicide committed in the course of an attempted burglary would constitute a defense to first degree murder arising out of the felony-murder rule. 162 W.Va. at 229 , 248 S.E.2d at 844 .

1986It is deemed sufficient if the homicide occurs accidentally during the commission of, or the attempt to commit, one of the enumerated felonies.” Specifically, this Court stated in Sims : The defendant’s trial counsel competently advised him as to the guilty plea, as there could be no reasonable expectation under the settled principles of our law that an unintended homicide committed in the course of an attempted burglary would constitute a defense to first degree murder arising out of the felony-murder rule. 162 W.Va. at 229 , 248 S.E.2d at 844 .

16
State v. Rodoussakisgreen
wva · 1998 · cited in 2 West Virginia opinions naming this issue, 2012–2019
2 sentences

2019Syllabus Point 3, State v. Rodoussakis, 204 W.Va. 58 , 511 S.E.2d 469 (1998); Syllabus Point 12, State v. Jenkins, 229 W.

2019Syllabus Point 3, State v. Rodoussakis, 204 W.Va. 58 , 511 S.E.2d 469 (1998); Syllabus Point 12, State v. Jenkins, 229 W.

12
State v. Younggreen
wva · 1983 · cited in 2 West Virginia opinions naming this issue, 1986–1998
2 sentences

1998However, this Court held in State v. Young, 173 W.Va. 1, 16-17 , 311 S.E.2d 118, 134 (1983) that under the felony murder rule "where a homicide occurs in the course of, or as a result of, a separate, distinct felony, the felonious intent involved in the underlying felony may be transferred to supply the intent to kill necessary to characterize the homicide as murder." (Citations omitted.) 4 .

1998However, this Court held in State v. Young, 173 W.Va. 1, 16-17 , 311 S.E.2d 118, 134 (1983) that under the felony murder rule "where a homicide occurs in the course of, or as a result of, a separate, distinct felony, the felonious intent involved in the underlying felony may be transferred to supply the intent to kill necessary to characterize the homicide as murder." (Citations omitted.) 4 .

12
Commonwealth v. Redlinegreen
pa · 1958 · cited in 2 West Virginia opinions naming this issue, 1978–1991
2 sentences

1991The mere coincidence of homicide and felony is not enough to satisfy the requirements of the felony-murder doctrine.” Commonwealth v. Redline, 391 Pa. 486 , 137 A.2d 472, 476 (1958). 1 A homicide may be murder of the first degree, of the second degree, or voluntary manslaughter or involuntary manslaughter or it may be justifiable.

1991The mere coincidence of homicide and felony is not enough to satisfy the requirements of the felony-murder doctrine.” Commonwealth v. Redline, 391 Pa. 486 , 137 A.2d 472, 476 (1958). 1 A homicide may be murder of the first degree, of the second degree, or voluntary manslaughter or involuntary manslaughter or it may be justifiable.

12
Head v. Stategreen
ind · 1982 · cited in 1 West Virginia opinions naming this issue, 2019–2019
1 sentence

2019See White v. State , 266 Ark. 499 , 585 S.W.2d 952 , 953-54 (1979). 11 See Kimbrough , 924 S.W.2d at 891-92 (providing that "[c]onsidering that the legislature has already enacted specific offenses covering situations in which death or injury is threatened or occurs during the commission of certain felonies, we conclude that to extend the felony-murder rule to cases in which no death occurs would 'extend the scope of the doctrine beyond the pale of its statutory design and logical underpinnings.' Head v. State , 443 N.E.2d 44 , 51 (Ind. 1982)."). 1 The Florida attempted felony murder statute,

11
State v. Darbygreen
njsuperctappdiv · 1984 · cited in 1 West Virginia opinions naming this issue, 2019–2019
2 sentences

2019See State v. Darby , 200 N.J.Super. 327 , 331, 491 A.2d 733 (App. Div. 1984) ('attempted felony murder' cannot be a crime because it is a self-contradiction; one does not intend an unintended result)."); State v. Ortega , 112 N.M. 554 , 817 P.2d 1196 , 1202 (1991) (acknowledging that crime of attempted felony murder is not recognized in New Mexico), abrogated on other grounds as stated in Kersey v. Hatch , 148 N.M. 381 , 237 P.3d 683 (2010) ; State v. Lea , 126 N.C.App. 440 , 485 S.E.2d 874 , 880 (1997) (holding that "offense of 'attempted first degree felony murder' does not exist" under Nort

2019See State v. Darby , 200 N.J.Super. 327 , 331, 491 A.2d 733 (App. Div. 1984) ('attempted felony murder' cannot be a crime because it is a self-contradiction; one does not intend an unintended result)."); State v. Ortega , 112 N.M. 554 , 817 P.2d 1196 , 1202 (1991) (acknowledging that crime of attempted felony murder is not recognized in New Mexico), abrogated on other grounds as stated in Kersey v. Hatch , 148 N.M. 381 , 237 P.3d 683 (2010) ; State v. Lea , 126 N.C.App. 440 , 485 S.E.2d 874 , 880 (1997) (holding that "offense of 'attempted first degree felony murder' does not exist" under Nort

11
White v. Statered
ark · 1979 · cited in 1 West Virginia opinions naming this issue, 2019–2019
2 sentences

2019See White v. State , 266 Ark. 499 , 585 S.W.2d 952 , 953-54 (1979). 11 See Kimbrough , 924 S.W.2d at 891-92 (providing that "[c]onsidering that the legislature has already enacted specific offenses covering situations in which death or injury is threatened or occurs during the commission of certain felonies, we conclude that to extend the felony-murder rule to cases in which no death occurs would 'extend the scope of the doctrine beyond the pale of its statutory design and logical underpinnings.' Head v. State , 443 N.E.2d 44 , 51 (Ind. 1982)."). 1 The Florida attempted felony murder statute,

2019See White v. State , 266 Ark. 499 , 585 S.W.2d 952 , 953-54 (1979). 11 See Kimbrough , 924 S.W.2d at 891-92 (providing that "[c]onsidering that the legislature has already enacted specific offenses covering situations in which death or injury is threatened or occurs during the commission of certain felonies, we conclude that to extend the felony-murder rule to cases in which no death occurs would 'extend the scope of the doctrine beyond the pale of its statutory design and logical underpinnings.' Head v. State , 443 N.E.2d 44 , 51 (Ind. 1982)."). 1 The Florida attempted felony murder statute,

11
State v. Kimbroughgreen
tenn · 1996 · cited in 1 West Virginia opinions naming this issue, 2019–2019
1 sentence

2019See White v. State , 266 Ark. 499 , 585 S.W.2d 952 , 953-54 (1979). 11 See Kimbrough , 924 S.W.2d at 891-92 (providing that "[c]onsidering that the legislature has already enacted specific offenses covering situations in which death or injury is threatened or occurs during the commission of certain felonies, we conclude that to extend the felony-murder rule to cases in which no death occurs would 'extend the scope of the doctrine beyond the pale of its statutory design and logical underpinnings.' Head v. State , 443 N.E.2d 44 , 51 (Ind. 1982)."). 1 The Florida attempted felony murder statute,

11
State v. Gaygreen
lactapp · 2002 · cited in 1 West Virginia opinions naming this issue, 2019–2019
1 sentence

2019It follows that a charge of attempted felony murder is illogical in that it burdens the State with the necessity of proving that the defendant intended to commit a crime that does not have an element of intent."); State v. Briggs, 218 Wis.2d 61 , 579 N.W.2d 783 , 786 (Ct. App. 1998) (determining that "there is no crime of attempted felony murder in the State of Wisconsin"); see also State v. Gay , 830 So.2d 356 , 364 (La.

11
State v. Knucklesgreen
wva · 1996 · cited in 1 West Virginia opinions naming this issue, 2018–2018
11
People v. Washingtongreen
cal · 1965 · cited in 1 West Virginia opinions naming this issue, 2012–2012
11
State v. Abbottgreen
wva · 1875 · cited in 1 West Virginia opinions naming this issue, 1999–1999
11
State v. Cookgreen
wva · 1985 · cited in 1 West Virginia opinions naming this issue, 1991–1991
11
State v. Stevensongreen
wva · 1962 · cited in 1 West Virginia opinions naming this issue, 1991–1991
11
State v. Shaffergreen
wva · 1953 · cited in 1 West Virginia opinions naming this issue, 1989–1989
11
State v. Paintergreen
wva · 1950 · cited in 1 West Virginia opinions naming this issue, 1989–1989
11
State v. Hallgreen
wva · 1982 · cited in 1 West Virginia opinions naming this issue, 1989–1989
11
State v. Lassitergreen
wva · 1987 · cited in 1 West Virginia opinions naming this issue, 1987–1987
11
State v. Petrygreen
wva · 1980 · cited in 1 West Virginia opinions naming this issue, 1985–1985
11
People v. Phillipsgreen
cal · 1966 · cited in 1 West Virginia opinions naming this issue, 1983–1983
11
People v. Salasgreen
cal · 1972 · cited in 1 West Virginia opinions naming this issue, 1982–1982
11
State v. Bragggreen
wva · 1955 · cited in 1 West Virginia opinions naming this issue, 1978–1978
11
State v. MacDonaldgreen
me · 1967 · cited in 1 West Virginia opinions naming this issue, 1978–1978
11

Distinguished, questioned or overruled (3)

CaseNegativeCited
Garringer v. Stategreen
haw · 1996 · cited in 2 West Virginia opinions naming this issue, 2015–2016
2 sentences

2016But see Garringer v. State, 909 P.2d 1142 , 1148–49 n.11 (Haw. 1996) (noting that Hawaii’s felony murder statute was repealed); Bennett v. Commonwealth, 978 S.W.2d 322, 327 (Ky. 1998) (“With the adoption of the penal code, the felony murder doctrine was abandoned as an independent basis for establishing an offense of homicide in Kentucky.”); People v. Aaron, 299 N.W.2d 304, 324 (Mich. 1980) (abolishing the common-law doctrine of felony murder).

2016But see Garringer v. State, 909 P.2d 1142 , 1148–49 n.11 (Haw. 1996) (noting that Hawaii’s felony murder statute was repealed); Bennett v. Commonwealth, 978 S.W.2d 322, 327 (Ky. 1998) (“With the adoption of the penal code, the felony murder doctrine was abandoned as an independent basis for establishing an offense of homicide in Kentucky.”); People v. Aaron, 299 N.W.2d 304, 324 (Mich. 1980) (abolishing the common-law doctrine of felony murder).

22
State v. Simsgreen
wva · 1978 · cited in 6 West Virginia opinions naming this issue, 1979–2012
2 sentences

1986It is deemed sufficient if the homicide occurs accidentally during the commission of, or the attempt to commit, one of the enumerated felonies.” Specifically, this Court stated in Sims : The defendant’s trial counsel competently advised him as to the guilty plea, as there could be no reasonable expectation under the settled principles of our law that an unintended homicide committed in the course of an attempted burglary would constitute a defense to first degree murder arising out of the felony-murder rule. 162 W.Va. at 229 , 248 S.E.2d at 844 .

1986It is deemed sufficient if the homicide occurs accidentally during the commission of, or the attempt to commit, one of the enumerated felonies.” Specifically, this Court stated in Sims : The defendant’s trial counsel competently advised him as to the guilty plea, as there could be no reasonable expectation under the settled principles of our law that an unintended homicide committed in the course of an attempted burglary would constitute a defense to first degree murder arising out of the felony-murder rule. 162 W.Va. at 229 , 248 S.E.2d at 844 .

16
State v. Grimmergreen
wva · 1979 · cited in 2 West Virginia opinions naming this issue, 1983–1985
2 sentences

1985It is deemed sufficient if the homicide occurs accidentally during the commission of, or the attempt to commit, one of the enumerated felonies." This holding, however, has been reaffirmed in State v. Wayne, 289 S.E.2d 480, 482 (W.Va.1982); State v. Hatfield, 286 S.E.2d 402 , 408 n. 2 (W.Va.1982); State v. Taylor, 285 S.E.2d 635, 637 (W.Va.1981); and, Syl. pt. 8, State v. Grimmer, 162 W.Va. 588 , 251 S.E.2d 780 (1979), overruled on other grounds, State v. Petry, 273 S.E.2d 346, 352 (W.Va.1980), and, as we tersely noted in thinly disguised exasperation in State v. Taylor, 285 S.E.2d at 637: "Onc

1985It is deemed sufficient if the homicide occurs accidentally during the commission of, or the attempt to commit, one of the enumerated felonies." This holding, however, has been reaffirmed in State v. Wayne, 289 S.E.2d 480, 482 (W.Va.1982); State v. Hatfield, 286 S.E.2d 402 , 408 n. 2 (W.Va.1982); State v. Taylor, 285 S.E.2d 635, 637 (W.Va.1981); and, Syl. pt. 8, State v. Grimmer, 162 W.Va. 588 , 251 S.E.2d 780 (1979), overruled on other grounds, State v. Petry, 273 S.E.2d 346, 352 (W.Va.1980), and, as we tersely noted in thinly disguised exasperation in State v. Taylor, 285 S.E.2d at 637: "Onc

12

Also cited on this issue (49)

CaseCitedYears
State Ex Rel. Peacher v. Sencindiver green
wva · 1977
2 sentences

1999Peacher v. Sencindiver, 160 W.Va. 314 , 233 S.E.2d 425 (1977).

1978Va. 585, 600 , 87 S.E.2d 689, 699 (1955), the Court examined the three statutory definitions of first degree murder. ‘... [T]his case was prosecuted on the theory that the defendant shot and killed Gullett in the commission of a robbery, [and] the question whether the killing was a “wilful, deliberate and premeditated” killing under Code 61-2-1, does not enter into this case.’ ” [ 233 S.E.2d at 426 ] Several cases from other jurisdictions were cited in Peacher and the following statement was made: “In none of these cases, however, did a court hold that application of the felony-murder rule den

21978–1999
State v. Pendry green
wva · 1976
2 sentences

1981Va. 738 , 227 S.E.2d 210 (1976), requested that we declare the felony-murder rule unconstitutional because it presumes a material element of murder-intent.

1978Ed. 2d 508 , 95 S.Ct. 1881 (1975), and State v. Pendry, _ W.Va. _, 227 S.E.2d 210 (1976).

21978–1981
State v. Swift green
· 1976
2 sentences

1978See State v. Goodseal, 220 Kan. 487 , 553 P.2d 279 (1976); State v. Swift, 290 N.C. 383 , 226 S.E.2d 652 (1976); and Warren v. State, 29 Md.App. 560 , 350 A.2d 173 (Ct.Spec.App.1976).

1978See State v. Goodseal, 220 Kan. 487 , 553 P.2d 279 (1976); State v. Swift, 290 N.C. 383 , 226 S.E.2d 652 (1976); and Warren v. State, 29 Md.App. 560 , 350 A.2d 173 (Ct.Spec.App.1976).

21977–1978
Warren v. State green
mdctspecapp · 1976
2 sentences

1978See State v. Goodseal, 220 Kan. 487 , 553 P.2d 279 (1976); State v. Swift, 290 N.C. 383 , 226 S.E.2d 652 (1976); and Warren v. State, 29 Md.App. 560 , 350 A.2d 173 (Ct.Spec.App.1976).

1978App. 560 , 350 A.2d 173 (1976), the court states: *226 “That reasoning was equally applicable to the common law felony-murder rule which requires no intent to kill or injure. “ ‘Even without an intent to kill or injure, or an act done in wanton and wilful disregard of the obvious likelihood of causing such harm, homicide is murder if it falls within the scope of the felony-murder rule.

21977–1978
State v. Williams green
wva · 1983
2 sentences

2021The circuit court noted that these convictions were obtained under the felony murder rule; accordingly, pursuant to State v. Williams, 172 W.

2021The trial court sentenced petitioner to life without mercy for each first-degree murder conviction, circuit court noted that these convictions were obtained tmder the felony murder rule; accordingly, pursuant to State v. Williams, 172 W.Va. 295 , 305 S.E.2d 251 (1983), petitioner was not sentenced for the underlying robbery or burglary convictions?

12021–2021
Goodson v. Commonwealth green
vactapp · 1996
2 sentences

2019Therefore, we also hold that attempted felony-murder does not exist as a crime in Utah."); Goodson v. Commonwealth , 22 Va.App. 61 , 467 S.E.2d 848 , 856 (1996) (concluding that "[t]o allow use of the felony murder doctrine to impute specific intent from the intent to commit the underlying felony [in an attempted felony-murder case] would eliminate the Commonwealth's burden to prove a specific intent to kill as an element of attempted murder."); In re Richey , 162 Wash.2d 865 , 175 P.3d 585 , 587 (2008) (concluding that the crime of attempted felony-murder does not exist in Washington because

2019Therefore, we also hold that attempted felony-murder does not exist as a crime in Utah."); Goodson v. Commonwealth , 22 Va.App. 61 , 467 S.E.2d 848 , 856 (1996) (concluding that "[t]o allow use of the felony murder doctrine to impute specific intent from the intent to commit the underlying felony [in an attempted felony-murder case] would eliminate the Commonwealth's burden to prove a specific intent to kill as an element of attempted murder."); In re Richey , 162 Wash.2d 865 , 175 P.3d 585 , 587 (2008) (concluding that the crime of attempted felony-murder does not exist in Washington because

12019–2019
Kersey v. Hatch green
nm · 2010
2 sentences

2019See State v. Darby , 200 N.J.Super. 327 , 331, 491 A.2d 733 (App. Div. 1984) ('attempted felony murder' cannot be a crime because it is a self-contradiction; one does not intend an unintended result)."); State v. Ortega , 112 N.M. 554 , 817 P.2d 1196 , 1202 (1991) (acknowledging that crime of attempted felony murder is not recognized in New Mexico), abrogated on other grounds as stated in Kersey v. Hatch , 148 N.M. 381 , 237 P.3d 683 (2010) ; State v. Lea , 126 N.C.App. 440 , 485 S.E.2d 874 , 880 (1997) (holding that "offense of 'attempted first degree felony murder' does not exist" under Nort

2019See State v. Darby , 200 N.J.Super. 327 , 331, 491 A.2d 733 (App. Div. 1984) ('attempted felony murder' cannot be a crime because it is a self-contradiction; one does not intend an unintended result)."); State v. Ortega , 112 N.M. 554 , 817 P.2d 1196 , 1202 (1991) (acknowledging that crime of attempted felony murder is not recognized in New Mexico), abrogated on other grounds as stated in Kersey v. Hatch , 148 N.M. 381 , 237 P.3d 683 (2010) ; State v. Lea , 126 N.C.App. 440 , 485 S.E.2d 874 , 880 (1997) (holding that "offense of 'attempted first degree felony murder' does not exist" under Nort

12019–2019
State v. Robinson green
kan · 1994
2 sentences

2019In other words, absent death the applicability of the felony-murder rule is never triggered."); State v. Robinson, 256 Kan. 133 , 883 P.2d 764 , 767 (1994) (stating that "Kansas does not recognize the crime of attempted felony murder."); Bruce v. State , 317 Md. 642 , 566 A.2d 103 , 105 (1989) (holding that "[b]ecause a conviction for felony murder requires no specific intent to kill, it follows that because a criminal attempt is a specific intent crime, attempted felony murder is not a crime in Maryland."); State v. Rhett , 127 N.J. 3 , 601 A.2d 689 , 692 (1992) (reversing attempted murder co

2019In other words, absent death the applicability of the felony-murder rule is never triggered."); State v. Robinson, 256 Kan. 133 , 883 P.2d 764 , 767 (1994) (stating that "Kansas does not recognize the crime of attempted felony murder."); Bruce v. State , 317 Md. 642 , 566 A.2d 103 , 105 (1989) (holding that "[b]ecause a conviction for felony murder requires no specific intent to kill, it follows that because a criminal attempt is a specific intent crime, attempted felony murder is not a crime in Maryland."); State v. Rhett , 127 N.J. 3 , 601 A.2d 689 , 692 (1992) (reversing attempted murder co

12019–2019
In re the Personal Restraint of Richey green
wash · 2008
12019–2019
Bruce v. State green
md · 1989
2 sentences

2019In other words, absent death the applicability of the felony-murder rule is never triggered."); State v. Robinson, 256 Kan. 133 , 883 P.2d 764 , 767 (1994) (stating that "Kansas does not recognize the crime of attempted felony murder."); Bruce v. State , 317 Md. 642 , 566 A.2d 103 , 105 (1989) (holding that "[b]ecause a conviction for felony murder requires no specific intent to kill, it follows that because a criminal attempt is a specific intent crime, attempted felony murder is not a crime in Maryland."); State v. Rhett , 127 N.J. 3 , 601 A.2d 689 , 692 (1992) (reversing attempted murder co

2019In other words, absent death the applicability of the felony-murder rule is never triggered."); State v. Robinson, 256 Kan. 133 , 883 P.2d 764 , 767 (1994) (stating that "Kansas does not recognize the crime of attempted felony murder."); Bruce v. State , 317 Md. 642 , 566 A.2d 103 , 105 (1989) (holding that "[b]ecause a conviction for felony murder requires no specific intent to kill, it follows that because a criminal attempt is a specific intent crime, attempted felony murder is not a crime in Maryland."); State v. Rhett , 127 N.J. 3 , 601 A.2d 689 , 692 (1992) (reversing attempted murder co

12019–2019
Commonwealth v. Griffin green
pasuperct · 1983
12019–2019
State v. Ortega green
nm · 1991
2 sentences

2019See State v. Darby , 200 N.J.Super. 327 , 331, 491 A.2d 733 (App. Div. 1984) ('attempted felony murder' cannot be a crime because it is a self-contradiction; one does not intend an unintended result)."); State v. Ortega , 112 N.M. 554 , 817 P.2d 1196 , 1202 (1991) (acknowledging that crime of attempted felony murder is not recognized in New Mexico), abrogated on other grounds as stated in Kersey v. Hatch , 148 N.M. 381 , 237 P.3d 683 (2010) ; State v. Lea , 126 N.C.App. 440 , 485 S.E.2d 874 , 880 (1997) (holding that "offense of 'attempted first degree felony murder' does not exist" under Nort

2019See State v. Darby , 200 N.J.Super. 327 , 331, 491 A.2d 733 (App. Div. 1984) ('attempted felony murder' cannot be a crime because it is a self-contradiction; one does not intend an unintended result)."); State v. Ortega , 112 N.M. 554 , 817 P.2d 1196 , 1202 (1991) (acknowledging that crime of attempted felony murder is not recognized in New Mexico), abrogated on other grounds as stated in Kersey v. Hatch , 148 N.M. 381 , 237 P.3d 683 (2010) ; State v. Lea , 126 N.C.App. 440 , 485 S.E.2d 874 , 880 (1997) (holding that "offense of 'attempted first degree felony murder' does not exist" under Nort

12019–2019
State v. Lea green
ncctapp · 1997
2 sentences

2019See State v. Darby , 200 N.J.Super. 327 , 331, 491 A.2d 733 (App. Div. 1984) ('attempted felony murder' cannot be a crime because it is a self-contradiction; one does not intend an unintended result)."); State v. Ortega , 112 N.M. 554 , 817 P.2d 1196 , 1202 (1991) (acknowledging that crime of attempted felony murder is not recognized in New Mexico), abrogated on other grounds as stated in Kersey v. Hatch , 148 N.M. 381 , 237 P.3d 683 (2010) ; State v. Lea , 126 N.C.App. 440 , 485 S.E.2d 874 , 880 (1997) (holding that "offense of 'attempted first degree felony murder' does not exist" under Nort

2019See State v. Darby , 200 N.J.Super. 327 , 331, 491 A.2d 733 (App. Div. 1984) ('attempted felony murder' cannot be a crime because it is a self-contradiction; one does not intend an unintended result)."); State v. Ortega , 112 N.M. 554 , 817 P.2d 1196 , 1202 (1991) (acknowledging that crime of attempted felony murder is not recognized in New Mexico), abrogated on other grounds as stated in Kersey v. Hatch , 148 N.M. 381 , 237 P.3d 683 (2010) ; State v. Lea , 126 N.C.App. 440 , 485 S.E.2d 874 , 880 (1997) (holding that "offense of 'attempted first degree felony murder' does not exist" under Nort

12019–2019
State v. Rhett green
nj · 1992
2 sentences

2019In other words, absent death the applicability of the felony-murder rule is never triggered."); State v. Robinson, 256 Kan. 133 , 883 P.2d 764 , 767 (1994) (stating that "Kansas does not recognize the crime of attempted felony murder."); Bruce v. State , 317 Md. 642 , 566 A.2d 103 , 105 (1989) (holding that "[b]ecause a conviction for felony murder requires no specific intent to kill, it follows that because a criminal attempt is a specific intent crime, attempted felony murder is not a crime in Maryland."); State v. Rhett , 127 N.J. 3 , 601 A.2d 689 , 692 (1992) (reversing attempted murder co

2019In other words, absent death the applicability of the felony-murder rule is never triggered."); State v. Robinson, 256 Kan. 133 , 883 P.2d 764 , 767 (1994) (stating that "Kansas does not recognize the crime of attempted felony murder."); Bruce v. State , 317 Md. 642 , 566 A.2d 103 , 105 (1989) (holding that "[b]ecause a conviction for felony murder requires no specific intent to kill, it follows that because a criminal attempt is a specific intent crime, attempted felony murder is not a crime in Maryland."); State v. Rhett , 127 N.J. 3 , 601 A.2d 689 , 692 (1992) (reversing attempted murder co

12019–2019
In Re Richey green
wash · 2008
1 sentence

2019Therefore, we also hold that attempted felony-murder does not exist as a crime in Utah."); Goodson v. Commonwealth , 22 Va.App. 61 , 467 S.E.2d 848 , 856 (1996) (concluding that "[t]o allow use of the felony murder doctrine to impute specific intent from the intent to commit the underlying felony [in an attempted felony-murder case] would eliminate the Commonwealth's burden to prove a specific intent to kill as an element of attempted murder."); In re Richey , 162 Wash.2d 865 , 175 P.3d 585 , 587 (2008) (concluding that the crime of attempted felony-murder does not exist in Washington because

12019–2019
State v. Briggs green
wisctapp · 1998
12019–2019
State v. Jenkins green
wva · 2012
1 sentence

2019Syllabus Point 3, State v. Rodoussakis, 204 W.Va. 58 , 511 S.E.2d 469 (1998); Syllabus Point 12, State v. Jenkins, 229 W.

12019–2019
State v. Nolan (Slip Opinion) green
ohio · 2014
12019–2019
Davis v. Fox green
wva · 2012
12017–2017
State v. England green
wva · 1988
11999–1999
State v. Cokeley green
wva · 1976
11991–1991
Local Lodge No. 1836, District 38, International Ass'n of Machinists v. Local No. 1505, International Brotherhood of Electrical Workers green
scotus · 1963
11991–1991
Missouri ex rel. Johnson v. Clay green
scotus · 1963
11991–1991
State v. Goff green
wva · 1976
11991–1991
State v. Hatfield green
wva · 1982
11985–1985
State v. Galloway green
iowa · 1979
11983–1983
Commonwealth Ex Rel. Smith v. Myers green
pa · 1970
11983–1983
State v. Downs green
ohio · 1977
11983–1983
State v. Lockett green
ohio · 1976
11983–1983
State v. Harrison red
nm · 1977
11983–1983
Lockett v. Ohio green
scotus · 1978
11983–1983
State v. Millette green
nh · 1972
11983–1983
Frazier v. United States green
scotus · 1978
11983–1983
Woods v. Ohio green
scotus · 1978
11983–1983
Bizup v. People green
colo · 1962
11982–1982
State v. Adams green
mo · 1936
11982–1982
State v. Artis green
nj · 1970
11982–1982
State v. Squire green
nc · 1977
11982–1982
Geer v. Bowers green
scotus · 1962
11982–1982
Pugh v. Virginia green
scotus · 1962
11982–1982

Statutes the citing opinions construe

WV § W. Va. Code § 61-2-1 (21) WV § W. Va. Code § 60A-4-401 (7) WV § W. Va. Code § 61-2-12 (6) WV § W. Va. Code § 61-2-9 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 2762 (1951–2026) NC 247 (1973–2026) IL 148 (1965–2025) KS 107 (1967–2022) PA 89 (1955–2026) FL 86 (1966–2025) MA 85 (1965–2024) TX 77 (1977–2026) AL 74 (1978–2026) MD 65 (1970–2024) IA 62 (1975–2025) TN 61 (1975–2025) MO 53 (1964–2020) AZ 52 (1965–2022) MI 49 (1963–2026) WA 42 (1961–2026) NV 38 (1965–2019) OH 35 (1980–2024) VA 33 (1978–2026) NM 32 (1960–2025) MN 29 (1979–2024) WV 28 (1977–2021) GA 27 (1975–2025) LA 25 (1961–2023) OK 24 (1983–2024) MT 23 (1976–2024) NJ 23 (1969–2022) NY 20 (1960–2019) OR 14 (1969–2026) WY 14 (1978–2025) ID 13 (1976–2024) CO 12 (1966–2025) IN 11 (1973–2019) CT 11 (1975–2025) MS 10 (1977–2013) DC 8 (1976–2020) AR 7 (1976–2025) SC 7 (1975–2018) DE 5 (1968–2022) RI 5 (1980–2023) UT 4 (1992–2003) VT 3 (1983–2017) VI 3 (2008–2017) SD 3 (1980–2002) WI 2 (1988–1994) NE 2 (1991–2019) KY 2 (2000–2001) AK 2 (1995–2018)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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