transferred intent doctrine (Kansas) · Go Syfert
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transferred intent doctrine in Kansas

9 Kansas opinions name it 2 courts 1991–2016 0 in the last five years

The cases below were cited by Kansas 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 (11)

CaseFollowedCited
State v. Jonesgreen
kan · 1995 · cited in 3 Kansas opinions naming this issue, 1996–2016
2 sentences

2012See State v. Jones, 257 Kan. 856, 859 , 896 P.2d 1077 (1995) (Under doctrine of transferred intent, the fact that a homicidal act was directed against one other than the person tolled does not relieve the slayer of criminal liability, and the guilt of the perpetrator of the crime is exactly what it would have been had the assault been upon the intended victim instead of another.).

2012See State v. Jones, 257 Kan. 856, 859 , 896 P.2d 1077 (1995) (Under doctrine of transferred intent, the fact that a homicidal act was directed against one other than the person tolled does not relieve the slayer of criminal liability, and the guilt of the perpetrator of the crime is exactly what it would have been had the assault been upon the intended victim instead of another.).

13
State v. Moffittgreen
kan · 1967 · cited in 2 Kansas opinions naming this issue, 1996–2016
2 sentences

2016It is generally held that such a homicide partakes of the quality of the original act, so that the guilt of the perpetrator of the crime is exactly what it would have been had the assault followed upon the intended victim instead of another." State v. Moffitt, 199 Kan. 514, 535 , 431 P.2d 879 (1967), overruled on other grounds by State v. Underwood, 228 Kan. 294, 306 , 615 P.2d 153 (1980).

2016Seba then supports his argument that felony murder must serve as the State's theory of prosecution by citing Moffitt, 199 Kan. at 529-30 , for its statement that "where any [definitions of murder and manslaughter at common law] are not in accord with our statutory provisions the latter must control." But Seba fails to point out how the transferred intent doctrine is not in accord with Kansas' first-degree murder statute.

12
State v. Garzagreen
kan · 1996 · cited in 2 Kansas opinions naming this issue, 1999–2001
2 sentences

2001In State v. Garza, 259 Kan. 826 , 916 P.2d 9 (1996), the court addressed the transferred intent doctrine in a shootout situation where another shooter’s bullet, not the defendant’s bullet, caused *709 a bystander s death.

2001In State v. Garza, 259 Kan. 826 , 916 P.2d 9 (1996), the court addressed the transferred intent doctrine in a shootout situation where another shooter’s bullet, not the defendant’s bullet, caused *709 a bystander s death.

12
United States v. Guillermo Novo Sampol, United States of America v. Alvin Ross Diaz, United States of America v. Ignacio Novo Sampolgreen
cadc · 1980 · cited in 1 Kansas opinions naming this issue, 2016–2016
1 sentence

2016Compare United States v. Sampol, 636 F.2d 621, 674 (D.C.

11
State v. Gaydengreen
kan · 1996 · cited in 1 Kansas opinions naming this issue, 2016–2016
2 sentences

2016Gladden, 273 Md. at 403-04 ; see also State v. Gayden, 259 Kan. 69, 76-78 , 910 P.2d 826 (1996).

2016Gladden, 273 Md. at 403-04 ; see also State v. Gayden, 259 Kan. 69, 76-78 , 910 P.2d 826 (1996).

11
State v. Thomasgreen
kan · 2015 · cited in 1 Kansas opinions naming this issue, 2016–2016
2 sentences

2016Jones, 257 Kan. at 870 ; see State v. Thomas, 302 Kan. 440 , Syl. ¶ 1, 353 P.3d 1134 (2015) ("Premeditated and felony murder are not separate and distinct offenses, but rather they are two theories under which the crime of first-degree murder may be committed.").

2016Jones, 257 Kan. at 870 ; see State v. Thomas, 302 Kan. 440 , Syl. ¶ 1, 353 P.3d 1134 (2015) ("Premeditated and felony murder are not separate and distinct offenses, but rather they are two theories under which the crime of first-degree murder may be committed.").

11
Rogers v. Stategreen
missctapp · 2008 · cited in 1 Kansas opinions naming this issue, 2012–2012
1 sentence

2012App. 3d 927, 936 , 799 N.E.2d 804 (2003) (“Under the doctrine of transferred intent, defendant can be exonerated if he shoots an assailant in self-defense but injures another; defendant’s intent to shoot his assailant in self-defense is transferred to the unintended victim.”); Rogers v. State, 994 So. 2d 792, 802 (Miss.

11
Holloman v. Stategreen
wyo · 2002 · cited in 1 Kansas opinions naming this issue, 2012–2012
1 sentence

2012App. 2008) (defendant could not be found guilty of aggravated assault of bystanders in bar when he fired handgun in self-defense and struck them while shooting at the person menacing him with a handgun); Clifton, 32 Ohio App. 2d at 287 (conviction reversed for failing to give jury instruction on transferred self-defense); Holloman v. State, 51 P.3d 214, 221 (Wyo. 2002) (“The general rule is that if a person acting in necessary self-defense unintentionally injures or kills a third person, he is not guilty of homicide or assault and battery.”).

11
State v. Cliftongreen
ohioctapp · 1972 · cited in 1 Kansas opinions naming this issue, 2012–2012
1 sentence

2012App. 2008) (defendant could not be found guilty of aggravated assault of bystanders in bar when he fired handgun in self-defense and struck them while shooting at the person menacing him with a handgun); Clifton, 32 Ohio App. 2d at 287 (conviction reversed for failing to give jury instruction on transferred self-defense); Holloman v. State, 51 P.3d 214, 221 (Wyo. 2002) (“The general rule is that if a person acting in necessary self-defense unintentionally injures or kills a third person, he is not guilty of homicide or assault and battery.”).

11
Morrow v. Floresgreen
texapp · 1949 · cited in 1 Kansas opinions naming this issue, 2007–2007
1 sentence

2007So, if one of two persons fighting unintentionally strikes a third, the person so striking is liable in an action by the third person for an assault and battery.’ ” (Emphasis added.) Morrow v. Flores, *764 225 S.W.2d 621, 624 (Tex. Civ.

11
People v. Lovettgreen
michctapp · 1979 · cited in 1 Kansas opinions naming this issue, 1991–1991
2 sentences

1991See People v. Lovett, 90 Mich. App. 169 , 283 N.W.2d 357 , lv. to appeal denied 407 Mich. 884 (1979), 8 A.L.R.4th 952 ; 2 Wharton’s Criminal Law § 144 (14th ed. 1979).

1991See People v. Lovett, 90 Mich. App. 169 , 283 N.W.2d 357 , lv. to appeal denied 407 Mich. 884 (1979), 8 A.L.R.4th 952 ; 2 Wharton’s Criminal Law § 144 (14th ed. 1979).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Kansas. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
State v. Stringfield green
kanctapp · 1980
2 sentences

2001App. 2d 559, 561, 608 P.2d 1041 , rev. denied 228 Kan. 807 (1980), the court applied the transferred intent doctrine to aggravated battery.

1996The Court of Appeals recognized that while a specific intent to injure was a necessary element of the aggravated battery, under the doctrine of transferred intent, the intent to injure could be transferred to a bystander who was unintentionally injured. 4 Kan.

21996–2001
Gladden v. State green
md · 1974
2 sentences

2016The court rejected the possibility that the codification of the elements of murder required abandonment of the transferred intent doctrine, concluding "its viability is recognized by its current acceptance and application." 273 Md. at 392 .

2016In contrast, many states with statutory provisions similar to Kansas'—i.e., defining the crime as "the killing of a human being" and without limitation to a specific victim—applied the transferred intent doctrine to premeditated murder. 273 Md. at 394 .

12016–2016
State v. Underwood green
kan · 1980
2 sentences

2016It is generally held that such a homicide partakes of the quality of the original act, so that the guilt of the perpetrator of the crime is exactly what it would have been had the assault followed upon the intended victim instead of another." State v. Moffitt, 199 Kan. 514, 535 , 431 P.2d 879 (1967), overruled on other grounds by State v. Underwood, 228 Kan. 294, 306 , 615 P.2d 153 (1980).

2016It is generally held that such a homicide partakes of the quality of the original act, so that the guilt of the perpetrator of the crime is exactly what it would have been had the assault followed upon the intended victim instead of another." State v. Moffitt, 199 Kan. 514, 535 , 431 P.2d 879 (1967), overruled on other grounds by State v. Underwood, 228 Kan. 294, 306 , 615 P.2d 153 (1980).

12016–2016
People v. Blue green
illappct · 2003
1 sentence

2012App. 3d 927, 936 , 799 N.E.2d 804 (2003) (“Under the doctrine of transferred intent, defendant can be exonerated if he shoots an assailant in self-defense but injures another; defendant’s intent to shoot his assailant in self-defense is transferred to the unintended victim.”); Rogers v. State, 994 So. 2d 792, 802 (Miss.

12012–2012
State v. Cordray green
kan · 2004
2 sentences

2012Perez cites State v. Cordray, 277 Kan. 43 , 82 P.3d 503 (2004), to support his argument that the evidence in his case reasonably justified a conviction of unintentional but reckless second-degree murder.

2012Perez cites State v. Cordray, 277 Kan. 43 , 82 P.3d 503 (2004), to support his argument that the evidence in his case reasonably justified a conviction of unintentional but reckless second-degree murder.

12012–2012

Statutes the citing opinions construe

KS § K.S.A. § 21-3211 (3) KS § K.S.A. § 21-3401 (3) KS § K.S.A. § 21-3402 (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 155 (1957–2026) IL 52 (1977–2026) TX 51 (1989–2025) PA 36 (1995–2026) OH 36 (1995–2026) GA 31 (1982–2026) WA 25 (1993–2026) MD 23 (1974–2019) FL 21 (1986–2026) MI 20 (1985–2026) IN 18 (1979–2020) LA 15 (1997–2026) SC 15 (1999–2025) CT 15 (1993–2023) MN 14 (1988–2026) VA 13 (1997–2025) NC 11 (1992–2025) MA 11 (2000–2023) DC 11 (1987–2022) AL 10 (1986–2023) TN 9 (1999–2019) KS 9 (1991–2016) WV 8 (1985–2020) MS 7 (2008–2024) NM 7 (1976–2020) NY 6 (1955–2019) AZ 5 (1990–2015) CO 5 (2007–2025) OR 5 (2013–2025) NE 4 (2006–2024) OK 4 (2016–2018) NJ 4 (2001–2020) KY 2 (1987–2023) ID 2 (2014–2014) NV 2 (1999–2018) MO 2 (2013–2025)

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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