felony-murder rule (Iowa) · Go Syfert
← Iowa issues

felony-murder rule in Iowa

62 Iowa opinions name it 2 courts 1975–2025 7 in the last five years

The cases below were cited by Iowa 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 (57)

CaseFollowedCited
State v. Heemstragreen
iowa · 2006 · cited in 29 Iowa opinions naming this issue, 2008–2025
2 sentences

2021While the direct appeal was pending, the Iowa Supreme Court decided State v. Heemstra, wherein the court overruled existing precedent relating to the felony-murder rule. 721 N.W.2d 549, 558 (Iowa 2006).

2020Cf. Phuoc Thanh Nguyen, 829 N.W.2d at 188 (discussing the felony-murder rule as law at the time of the defendant’s conviction and our decision in State v. Heemstra, 721 N.W.2d 549 (Iowa 2006) was not 8 “simply a ‘clarification of the law’ or ‘an application of preexisting law’ ” but an express overruling of prior law (quoting Perez v. State, 829 N.W.2d 354 , 360–61 (Iowa 2012))).

2229
State v. Beemangreen
iowa · 1982 · cited in 8 Iowa opinions naming this issue, 1983–2016
2 sentences

2016The underlying predicate felony was terrorism. 1 The use of an assaultive predicate felony was supported by a line of cases starting with State v. Beeman, which found willful injury to be a proper predicate felony for a felony-murder instruction. 315 N.W.2d 770, 776 (Iowa 1982).

2016In Beeman, the court held that Iowa’s first-degree murder statute made willful injury a proper predicate felony for a felony- murder instruction. 315 N.W.2d at 776 .

88
State v. Raglandgreen
iowa · 1988 · cited in 7 Iowa opinions naming this issue, 1988–2018
2 sentences

2018We came to a similar conclusion in State v. Ragland , 420 N.W.2d 791 , 794 (Iowa 1988), overruled on other grounds by State v. Heemstra , 721 N.W.2d 549 , 558 (Iowa 2006).

1988In State v. Ragland, 420 N.W. 2d 791, 794 (Iowa 1988), we determined that the felony-murder rule does not violate due process when the underlying felony is willful injury under Iowa Code section 708.-4.

67
State Of Iowa Vs. Stanley Alan Tribblegreen
iowa · 2010 · cited in 6 Iowa opinions naming this issue, 2016–2024
2 sentences

2024The Iowa Code defines murder as killing “another person with malice aforethought either express or implied.” Iowa Code § 707.1 . “[A] person commits murder in the first degree under the felony-murder rule in Iowa when the person kills another person (with expressed or implied malice aforethought) while participating in a nonexempt forcible felony.” State v. Tribble, 790 N.W.2d 121, 125 (Iowa 2010); see also Iowa Code §§ 707.1 , .2(1)(b).

2020The felony-murder rule developed from a common-law doctrine “that any death resulting from the commission or attempted commission of a felony constitutes murder.” State v. Tribble, 790 N.W.2d 121, 124 (Iowa 2010).

56
State of Iowa v. Keyon Harrisongreen
iowa · 2018 · cited in 4 Iowa opinions naming this issue, 2018–2022
2 sentences

2022“The felony-murder rule aims to deter people from committing those felonies the legislature has deemed inherently dangerous to the life of others.” State v. Harrison, 914 N.W.2d 178, 191 (Iowa 2018).

2021See State v. Harrison, 914 N.W.2d 178, 196 (Iowa 2018) (“Further, Harrison misrepresents the felony-murder rule in his argument that it is premised on the ability to foresee danger.

34
State of Iowa v. Jeffrey K. Raglandgreen
iowa · 2013 · cited in 3 Iowa opinions naming this issue, 2018–2018
2 sentences

2018See State v. Roby, 897 N.W.2d 127, 135 (Iowa 2017); State v. Sweet, 879 N.W.2d 811, 839 (Iowa 2016); State v. Louisell, 865 N.W.2d 590, 603 (Iowa 2015); State v. Seats, 865 N.W.2d 545, 555-58 (Iowa 2015); Lyle, 854 N.W.2d at 400-04 ; State v. Null, 836 N.W.2d 41, 74-75 (Iowa 2013); State v. Pearson, 836 N.W.2d 88, 95-98 (Iowa 2013); State v. Ragland, 836 N.W.2d 107, 121-22 (Iowa 2013); see also State v. Harrison, 914 N.W.2d 178, 188-202 (Iowa 2018) (discussing in depth the state and federal sentencing landscape for juvenile offenders, application of the felony-murder rule to juvenile offenders

2018In Ragland , a child knowingly participated in a fight with a rival group of children. 836 N.W.2d 107 , 110 (Iowa 2013).

33
Conner v. Stategreen
iowa · 1985 · cited in 3 Iowa opinions naming this issue, 1997–2018
2 sentences

2018In Conner, we departed from the transferred-intent model of analysis, which would have exposed the felony-murder rule to due process attack, and instead declared that elimination of the mens rea requirement 53 was not an irrebuttable presumption but instead “a matter of substantive law that places responsibility on a wrongdoer for the direct and indirect consequences of his joint criminal conduct with another.” Id. at 456.

2018In Conner , we departed from the transferred-intent model of analysis, which would have exposed the felony-murder rule to due process attack, and instead declared that elimination of the mens rea requirement was not an irrebuttable presumption *213 but instead "a matter of substantive law that places responsibility on a wrongdoer for the direct and indirect consequences of his joint criminal conduct with another." Id. at 456 .

33
Phuoc Thanh Nguyen v. State of Iowagreen
iowa · 2013 · cited in 4 Iowa opinions naming this issue, 2015–2020
2 sentences

2020Cf. Phuoc Thanh Nguyen, 829 N.W.2d at 188 (discussing the felony-murder rule as law at the time of the defendant’s conviction and our decision in State v. Heemstra, 721 N.W.2d 549 (Iowa 2006) was not 8 “simply a ‘clarification of the law’ or ‘an application of preexisting law’ ” but an express overruling of prior law (quoting Perez v. State, 829 N.W.2d 354 , 360–61 (Iowa 2012))).

2016See Nguyen, 829 N.W.2d at 186 (noting Nguyen filed his PCR action within three years of State v. Heemstra, 721 N.W.2d 549 (Iowa 2006), the case that changed the law with respect to the felony-murder rule).

24
State v. Camposgreen
nm · 1996 · cited in 2 Iowa opinions naming this issue, 2018–2018
2 sentences

2018Nor is the burden of proof as to an element of the crime charged 'affirmatively shifted' from the Commonwealth to the defendant as prohibited by the Supreme Court in Mullaney v. Wilbur , 421 U.S. 684 , 701, 95 S.Ct. 1881 , 44 L.Ed. 2d 508 (1975)."); State v. Burkhart , 325 Mont. 27 , 103 P.3d 1037 , 1046-47 (2004) (holding the felony-murder rule does not violate due process since intent to kill is not an element of the crime under the felony-murder rule); State v. Bradley , 210 Neb. 882 , 317 N.W.2d 99 , 101-02 (1982) (rejecting defendant's argument that the felony-murder rule conclusively pre

2018Nor is the burden of proof as to an element of the crime charged 'affirmatively shifted' from the Commonwealth to the defendant as prohibited by the Supreme Court in Mullaney v. Wilbur , 421 U.S. 684 , 701, 95 S.Ct. 1881 , 44 L.Ed. 2d 508 (1975)."); State v. Burkhart , 325 Mont. 27 , 103 P.3d 1037 , 1046-47 (2004) (holding the felony-murder rule does not violate due process since intent to kill is not an element of the crime under the felony-murder rule); State v. Bradley , 210 Neb. 882 , 317 N.W.2d 99 , 101-02 (1982) (rejecting defendant's argument that the felony-murder rule conclusively pre

22
Roper v. Simmonsgreen
scotus · 2005 · cited in 2 Iowa opinions naming this issue, 2018–2018
2 sentences

2018An overview of these changes is necessary to provide background for our analysis of Harrison’s constitutional challenge to the felony-murder rule and his sentence of life imprisonment with immediate parole eligibility. 9 First, in Roper, the Supreme Court held that imposing capital punishment on juvenile offenders constitutes cruel and unusual punishment under the Eighth Amendment. 543 U.S. at 568 , 126 S. Ct. at 1194.

2018An overview of these changes is necessary to provide background for our analysis of Harrison’s constitutional challenge to the felony-murder rule and his sentence of life imprisonment with immediate parole eligibility. 9 First, in Roper, the Supreme Court held that imposing capital punishment on juvenile offenders constitutes cruel and unusual punishment under the Eighth Amendment. 543 U.S. at 568 , 126 S. Ct. at 1194.

22
People v. Aarongreen
mich · 1980 · cited in 2 Iowa opinions naming this issue, 2018–2018
22
State v. Wanrowred
wash · 1978 · cited in 2 Iowa opinions naming this issue, 2018–2018
2 sentences

2018Our felony-murder rule only serves to raise second-degree murder to first-degree murder when the murder is committed in the course of a dangerous felony." (Citation omitted.)); State v. Swift , 290 N.C. 383 , 226 S.E.2d 652 , 668-69 (1976) (holding the felony-murder rule does not involve any presumption of premeditation and deliberation that would violate the Due Process Clause of the Fourteenth Amendment because those are not elements of the crime of felony murder); Gore v. Leeke , 261 S.C. 308 , 199 S.E.2d 755 , 757 (1973) (holding the felony-murder rule did not violate the Due Process Claus

2018Our felony-murder rule only serves to raise second-degree murder to first-degree murder when the murder is committed in the course of a dangerous felony." (Citation omitted.)); State v. Swift , 290 N.C. 383 , 226 S.E.2d 652 , 668-69 (1976) (holding the felony-murder rule does not involve any presumption of premeditation and deliberation that would violate the Due Process Clause of the Fourteenth Amendment because those are not elements of the crime of felony murder); Gore v. Leeke , 261 S.C. 308 , 199 S.E.2d 755 , 757 (1973) (holding the felony-murder rule did not violate the Due Process Claus

22
People v. Phillipsgreen
cal · 1966 · cited in 2 Iowa opinions naming this issue, 2018–2018
22
Gore v. Leekegreen
· 1973 · cited in 2 Iowa opinions naming this issue, 2018–2018
2 sentences

2018Our felony-murder rule only serves to raise second-degree murder to first-degree murder when the murder is committed in the course of a dangerous felony." (Citation omitted.)); State v. Swift , 290 N.C. 383 , 226 S.E.2d 652 , 668-69 (1976) (holding the felony-murder rule does not involve any presumption of premeditation and deliberation that would violate the Due Process Clause of the Fourteenth Amendment because those are not elements of the crime of felony murder); Gore v. Leeke , 261 S.C. 308 , 199 S.E.2d 755 , 757 (1973) (holding the felony-murder rule did not violate the Due Process Claus

2018Our felony-murder rule only serves to raise second-degree murder to first-degree murder when the murder is committed in the course of a dangerous felony." (Citation omitted.)); State v. Swift , 290 N.C. 383 , 226 S.E.2d 652 , 668-69 (1976) (holding the felony-murder rule does not involve any presumption of premeditation and deliberation that would violate the Due Process Clause of the Fourteenth Amendment because those are not elements of the crime of felony murder); Gore v. Leeke , 261 S.C. 308 , 199 S.E.2d 755 , 757 (1973) (holding the felony-murder rule did not violate the Due Process Claus

22
Commonwealth v. Watkinsgreen
mass · 1978 · cited in 2 Iowa opinions naming this issue, 2018–2018
2 sentences

2018See, e.g. , State v. Herrera , 176 Ariz. 21 , 859 P.2d 131 , 140 (1993) (en banc) (rejecting a constitutional challenge to the Arizona felony-murder rule that claimed the rule unconstitutionally presumed the defendant's intent to kill based on the intent to commit the underlying felony); Dillon , 194 Cal.Rptr. 390 , 668 P.2d at 717-18 (holding the felony-murder rule does not create a conclusive presumption of the existence of an element of the crime in violation of the Due Process Clause of the Fourteenth Amendment since malice aforethought is not an element of felony murder); State v. Goodsea

2018See, e.g. , State v. Herrera , 176 Ariz. 21 , 859 P.2d 131 , 140 (1993) (en banc) (rejecting a constitutional challenge to the Arizona felony-murder rule that claimed the rule unconstitutionally presumed the defendant's intent to kill based on the intent to commit the underlying felony); Dillon , 194 Cal.Rptr. 390 , 668 P.2d at 717-18 (holding the felony-murder rule does not create a conclusive presumption of the existence of an element of the crime in violation of the Due Process Clause of the Fourteenth Amendment since malice aforethought is not an element of felony murder); State v. Goodsea

22
State v. Goodsealgreen
kan · 1976 · cited in 2 Iowa opinions naming this issue, 2018–2018
2 sentences

2018See, e.g. , State v. Herrera , 176 Ariz. 21 , 859 P.2d 131 , 140 (1993) (en banc) (rejecting a constitutional challenge to the Arizona felony-murder rule that claimed the rule unconstitutionally presumed the defendant's intent to kill based on the intent to commit the underlying felony); Dillon , 194 Cal.Rptr. 390 , 668 P.2d at 717-18 (holding the felony-murder rule does not create a conclusive presumption of the existence of an element of the crime in violation of the Due Process Clause of the Fourteenth Amendment since malice aforethought is not an element of felony murder); State v. Goodsea

2018See, e.g. , State v. Herrera , 176 Ariz. 21 , 859 P.2d 131 , 140 (1993) (en banc) (rejecting a constitutional challenge to the Arizona felony-murder rule that claimed the rule unconstitutionally presumed the defendant's intent to kill based on the intent to commit the underlying felony); Dillon , 194 Cal.Rptr. 390 , 668 P.2d at 717-18 (holding the felony-murder rule does not create a conclusive presumption of the existence of an element of the crime in violation of the Due Process Clause of the Fourteenth Amendment since malice aforethought is not an element of felony murder); State v. Goodsea

22
Commonwealth Ex Rel. Smith v. Myersgreen
pa · 1970 · cited in 2 Iowa opinions naming this issue, 2018–2018
22
State v. Herrera, Jr.green
ariz · 1993 · cited in 2 Iowa opinions naming this issue, 2018–2018
2 sentences

2018See, e.g. , State v. Herrera , 176 Ariz. 21 , 859 P.2d 131 , 140 (1993) (en banc) (rejecting a constitutional challenge to the Arizona felony-murder rule that claimed the rule unconstitutionally presumed the defendant's intent to kill based on the intent to commit the underlying felony); Dillon , 194 Cal.Rptr. 390 , 668 P.2d at 717-18 (holding the felony-murder rule does not create a conclusive presumption of the existence of an element of the crime in violation of the Due Process Clause of the Fourteenth Amendment since malice aforethought is not an element of felony murder); State v. Goodsea

2018See, e.g. , State v. Herrera , 176 Ariz. 21 , 859 P.2d 131 , 140 (1993) (en banc) (rejecting a constitutional challenge to the Arizona felony-murder rule that claimed the rule unconstitutionally presumed the defendant's intent to kill based on the intent to commit the underlying felony); Dillon , 194 Cal.Rptr. 390 , 668 P.2d at 717-18 (holding the felony-murder rule does not create a conclusive presumption of the existence of an element of the crime in violation of the Due Process Clause of the Fourteenth Amendment since malice aforethought is not an element of felony murder); State v. Goodsea

22
State v. Taylorgreen
iowa · 1980 · cited in 2 Iowa opinions naming this issue, 2018–2018
22
State v. Jeffersongreen
ncctapp · 2017 · cited in 2 Iowa opinions naming this issue, 2018–2018
22
State of Iowa v. Sayvon Andre Proppsgreen
iowa · 2017 · cited in 2 Iowa opinions naming this issue, 2018–2018
22
State v. Rhodegreen
iowactapp · 1993 · cited in 2 Iowa opinions naming this issue, 2017–2017
22
Goosman v. Stategreen
iowa · 2009 · cited in 2 Iowa opinions naming this issue, 2017–2017
22
State v. Olivergreen
iowa · 1983 · cited in 2 Iowa opinions naming this issue, 2015–2015
22
State v. Mayberrygreen
iowa · 1987 · cited in 2 Iowa opinions naming this issue, 1994–2013
22
State v. Buggsgreen
tenn · 1999 · cited in 2 Iowa opinions naming this issue, 2010–2010
22
Commonwealth v. Claudiogreen
mass · 1994 · cited in 2 Iowa opinions naming this issue, 2006–2006
22
State v. Williamsgreen
iowa · 1979 · cited in 2 Iowa opinions naming this issue, 2006–2006
22
State v. Connergreen
iowa · 1976 · cited in 2 Iowa opinions naming this issue, 1978–1985
22
State v. Nowlingreen
iowa · 1976 · cited in 3 Iowa opinions naming this issue, 2012–2018
2 sentences

2018Nowlin , 244 N.W.2d at 604 -05 .

2012See State v. Nowlin, 244 N.W.2d 596, 605 (Iowa 1976) (finding the felony murder rule constitutional because the State must still prove every element, including the element of intent in the underlying crime, to enhance the degree of murder).

13
Schrier v. Stategreen
iowa · 1984 · cited in 3 Iowa opinions naming this issue, 1999–2018
2 sentences

2018Thus, in State v. Taylor, 287 N.W.2d 576, 578 (Iowa 1980), we again stated that malice may be shown by the commission of a felony, and in Schrier v. State, 347 N.W.2d 657 , 666–67 (Iowa 1984), we held that counsel was not ineffective for failing to object to a felony-murder instruction that allowed the state to prove malice simply by proving an underlying felony.

2018Thus, in State v. Taylor , 287 N.W.2d 576 , 578 (Iowa 1980), we again stated that malice may be shown by the commission of a felony, and in Schrier v. State , 347 N.W.2d 657 , 666-67 (Iowa 1984), we held that counsel was not ineffective for failing to object to a felony-murder instruction that allowed the state to prove malice simply by proving an underlying felony.

13
Enmund v. Floridagreen
scotus · 1982 · cited in 3 Iowa opinions naming this issue, 2013–2018
2 sentences

2018As was powerfully pointed out in Enmund , it is hard to understand how the felony-murder rule deters when the defendant has no intention to commit the crime. 458 U.S. at 798 -99 , 102 S.Ct. at 3377 .

2018As was powerfully pointed out in Enmund , it is hard to understand how the felony-murder rule deters when the defendant has no intention to commit the crime. 458 U.S. at 798 -99 , 102 S.Ct. at 3377 .

13
State v. Ortegagreen
nm · 1991 · cited in 2 Iowa opinions naming this issue, 2018–2018
2 sentences

2018Id. at 1205 .

2018Id. at 1205.

12
People v. Dillongreen
cal · 1983 · cited in 2 Iowa opinions naming this issue, 2018–2018
2 sentences

2018See, e.g. , State v. Herrera , 176 Ariz. 21 , 859 P.2d 131 , 140 (1993) (en banc) (rejecting a constitutional challenge to the Arizona felony-murder rule that claimed the rule unconstitutionally presumed the defendant's intent to kill based on the intent to commit the underlying felony); Dillon , 194 Cal.Rptr. 390 , 668 P.2d at 717-18 (holding the felony-murder rule does not create a conclusive presumption of the existence of an element of the crime in violation of the Due Process Clause of the Fourteenth Amendment since malice aforethought is not an element of felony murder); State v. Goodsea

2018See, e.g. , State v. Herrera , 176 Ariz. 21 , 859 P.2d 131 , 140 (1993) (en banc) (rejecting a constitutional challenge to the Arizona felony-murder rule that claimed the rule unconstitutionally presumed the defendant's intent to kill based on the intent to commit the underlying felony); Dillon , 194 Cal.Rptr. 390 , 668 P.2d at 717-18 (holding the felony-murder rule does not create a conclusive presumption of the existence of an element of the crime in violation of the Due Process Clause of the Fourteenth Amendment since malice aforethought is not an element of felony murder); State v. Goodsea

12
People v. Washingtongreen
cal · 1965 · cited in 2 Iowa opinions naming this issue, 2006–2012
12
Nay v. Stategreen
nev · 2007 · cited in 2 Iowa opinions naming this issue, 2010–2010
12
People v. Irelandgreen
cal · 1969 · cited in 2 Iowa opinions naming this issue, 2006–2006
12
Snethen v. Stategreen
iowa · 1981 · cited in 1 Iowa opinions naming this issue, 2019–2019
11
State of Iowa v. Denem Anthony Nullgreen
iowa · 2013 · cited in 1 Iowa opinions naming this issue, 2018–2018
11
State of Iowa v. Desirae Monique Pearsongreen
iowa · 2013 · cited in 1 Iowa opinions naming this issue, 2018–2018
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (23)

CaseCitedYears
State v. Lyle green
iowa · 2014
2 sentences

2018Specifically, Harrison alleges the felony-murder rule is premised on the assumption that juvenile offenders who participate in a forcible felony can appreciate the potential consequences of their participation even though juvenile offenders are "not developed enough to appreciate not only the assumption, but the natural consequence of the [forcible felony] (i.e. the murder)." Harrison relies primarily on our state and federal juvenile sentencing jurisprudence which recognizes that there is a "fundamental and virtually inexorable difference between juveniles and adults for the purposes of punis

2018Rather, he largely repeats the same argument he made with regard to banning the application of the felony-murder rule to juveniles-namely, that "juveniles lack the ability to form the proper foreseeability, lack the appreciation of consequences, and are highly impulsive." However, we held in Propps that "[t]he constitutional analysis is not about excusing juvenile behavior, but imposing punishment in a way that is consistent with our understanding of humanity today." Propps , 897 N.W.2d at 102 (alteration in original) (quoting Lyle , 854 N.W.2d at 398 ).

32018–2018
State v. Tucker green
iowactapp · 2012
2 sentences

2017Id. at 522 .

2016Tucker, 810 N.W.2d at 522 .

32015–2017
Graham v. Florida green
scotus · 2010
22018–2018
State v. Swift green
· 1976
2 sentences

2018Our felony-murder rule only serves to raise second-degree murder to first-degree murder when the murder is committed in the course of a dangerous felony." (Citation omitted.)); State v. Swift , 290 N.C. 383 , 226 S.E.2d 652 , 668-69 (1976) (holding the felony-murder rule does not involve any presumption of premeditation and deliberation that would violate the Due Process Clause of the Fourteenth Amendment because those are not elements of the crime of felony murder); Gore v. Leeke , 261 S.C. 308 , 199 S.E.2d 755 , 757 (1973) (holding the felony-murder rule did not violate the Due Process Claus

2018Our felony-murder rule only serves to raise second-degree murder to first-degree murder when the murder is committed in the course of a dangerous felony." (Citation omitted.)); State v. Swift , 290 N.C. 383 , 226 S.E.2d 652 , 668-69 (1976) (holding the felony-murder rule does not involve any presumption of premeditation and deliberation that would violate the Due Process Clause of the Fourteenth Amendment because those are not elements of the crime of felony murder); Gore v. Leeke , 261 S.C. 308 , 199 S.E.2d 755 , 757 (1973) (holding the felony-murder rule did not violate the Due Process Claus

22018–2018
State v. Burkhart green
mont · 2004
22018–2018
State of Iowa v. Charles James David Oliver green
iowa · 2012
2 sentences

2018Louisell, 865 N.W.2d at 600 . “[W]e owe substantial deference to the penalties the legislature has established for various crimes.” Oliver, 812 N.W.2d at 650 .

2018Louisell , 865 N.W.2d at 600 . "[W]e owe substantial deference to the penalties the legislature has established for various crimes." Oliver , 812 N.W.2d at 650 .

22018–2018
Miller v. Alabama green
scotus · 2012
2 sentences

2018Va. 1977) (rejecting a constitutional challenge to the felony-murder rule under the Due Process Clauses because the felony-murder rule does not require a showing of malice and therefore does not create a presumption that defendant committed the killing with malice). 20 132 S. Ct. at 2464 ), for sentencing purposes due to “the features of youthful behavior, such as ‘immaturity, impetuosity, and failure to appreciate risks and consequences.’ ” Lyle, 854 N.W.2d at 404 n.10 (quoting Miller, 567 U.S. at 477 , 132 S. Ct. at 2468 ).

2018Va. 1977) (rejecting a constitutional challenge to the felony-murder rule under the Due Process Clauses because the felony-murder rule does not require a showing of malice and therefore does not create a presumption that defendant committed the killing with malice). 20 132 S. Ct. at 2464 ), for sentencing purposes due to “the features of youthful behavior, such as ‘immaturity, impetuosity, and failure to appreciate risks and consequences.’ ” Lyle, 854 N.W.2d at 404 n.10 (quoting Miller, 567 U.S. at 477 , 132 S. Ct. at 2468 ).

22018–2018
State v. Underwood green
kan · 1980
2 sentences

2018See, e.g. , State v. Herrera , 176 Ariz. 21 , 859 P.2d 131 , 140 (1993) (en banc) (rejecting a constitutional challenge to the Arizona felony-murder rule that claimed the rule unconstitutionally presumed the defendant's intent to kill based on the intent to commit the underlying felony); Dillon , 194 Cal.Rptr. 390 , 668 P.2d at 717-18 (holding the felony-murder rule does not create a conclusive presumption of the existence of an element of the crime in violation of the Due Process Clause of the Fourteenth Amendment since malice aforethought is not an element of felony murder); State v. Goodsea

2018See, e.g. , State v. Herrera , 176 Ariz. 21 , 859 P.2d 131 , 140 (1993) (en banc) (rejecting a constitutional challenge to the Arizona felony-murder rule that claimed the rule unconstitutionally presumed the defendant's intent to kill based on the intent to commit the underlying felony); Dillon , 194 Cal.Rptr. 390 , 668 P.2d at 717-18 (holding the felony-murder rule does not create a conclusive presumption of the existence of an element of the crime in violation of the Due Process Clause of the Fourteenth Amendment since malice aforethought is not an element of felony murder); State v. Goodsea

22018–2018
State v. Bradley green
neb · 1982
2 sentences

2018Nor is the burden of proof as to an element of the crime charged 'affirmatively shifted' from the Commonwealth to the defendant as prohibited by the Supreme Court in Mullaney v. Wilbur , 421 U.S. 684 , 701, 95 S.Ct. 1881 , 44 L.Ed. 2d 508 (1975)."); State v. Burkhart , 325 Mont. 27 , 103 P.3d 1037 , 1046-47 (2004) (holding the felony-murder rule does not violate due process since intent to kill is not an element of the crime under the felony-murder rule); State v. Bradley , 210 Neb. 882 , 317 N.W.2d 99 , 101-02 (1982) (rejecting defendant's argument that the felony-murder rule conclusively pre

2018Nor is the burden of proof as to an element of the crime charged 'affirmatively shifted' from the Commonwealth to the defendant as prohibited by the Supreme Court in Mullaney v. Wilbur , 421 U.S. 684 , 701, 95 S.Ct. 1881 , 44 L.Ed. 2d 508 (1975)."); State v. Burkhart , 325 Mont. 27 , 103 P.3d 1037 , 1046-47 (2004) (holding the felony-murder rule does not violate due process since intent to kill is not an element of the crime under the felony-murder rule); State v. Bradley , 210 Neb. 882 , 317 N.W.2d 99 , 101-02 (1982) (rejecting defendant's argument that the felony-murder rule conclusively pre

22018–2018
People v. Flood green
cal · 1998
2 sentences

2018As noted by one court, "the felony murder doctrine expresses a highly artificial concept that deserves no extension beyond its required application." People v. Phillips , 64 Cal.2d 574 , 51 Cal.Rptr. 225 , 414 P.2d 353 , 360 (1966) (en banc), overruled on other grounds by People v. Flood , 18 Cal.4th 470 , 76 Cal.Rptr.2d 180 , 957 P.2d 869 , 882 n.12 (1998).

2018As noted by one court, "the felony murder doctrine expresses a highly artificial concept that deserves no extension beyond its required application." People v. Phillips , 64 Cal.2d 574 , 51 Cal.Rptr. 225 , 414 P.2d 353 , 360 (1966) (en banc), overruled on other grounds by People v. Flood , 18 Cal.4th 470 , 76 Cal.Rptr.2d 180 , 957 P.2d 869 , 882 n.12 (1998).

22018–2018
In Re WINSHIP green
scotus · 1970
2 sentences

2018See, e.g. , State v. Herrera , 176 Ariz. 21 , 859 P.2d 131 , 140 (1993) (en banc) (rejecting a constitutional challenge to the Arizona felony-murder rule that claimed the rule unconstitutionally presumed the defendant's intent to kill based on the intent to commit the underlying felony); Dillon , 194 Cal.Rptr. 390 , 668 P.2d at 717-18 (holding the felony-murder rule does not create a conclusive presumption of the existence of an element of the crime in violation of the Due Process Clause of the Fourteenth Amendment since malice aforethought is not an element of felony murder); State v. Goodsea

2018See, e.g. , State v. Herrera , 176 Ariz. 21 , 859 P.2d 131 , 140 (1993) (en banc) (rejecting a constitutional challenge to the Arizona felony-murder rule that claimed the rule unconstitutionally presumed the defendant's intent to kill based on the intent to commit the underlying felony); Dillon , 194 Cal.Rptr. 390 , 668 P.2d at 717-18 (holding the felony-murder rule does not create a conclusive presumption of the existence of an element of the crime in violation of the Due Process Clause of the Fourteenth Amendment since malice aforethought is not an element of felony murder); State v. Goodsea

22018–2018
In Re Personal Restraint of Andress red
wash · 2002
22018–2018
Evans v. State green
mdctspecapp · 1975
22018–2018
Tison v. Arizona green
scotus · 1987
22018–2018
State of Minnesota v. Mahdi Hassan Ali green
minn · 2014
2 sentences

2018Ct. App. 2012) (declining to adopt a categorical rule prohibiting the sentence of life imprisonment without the possibility of parole for juvenile offenders convicted under the felony-murder rule); State v. Ali, 855 N.W.2d 235 , 258–59 (Minn. 25 national consensus remains in favor of subjecting juvenile offenders convicted of first-degree murder under the felony-murder rule—regardless of whether an offender was aiding and abetting or the principal actor—to the same sentencing options as juvenile offenders convicted of premeditated first-degree murder. 8 2014) (noting the constitutionality of l

2018Ct. App. 2012) (declining to adopt a categorical rule prohibiting the sentence of life imprisonment without the possibility of parole for juvenile offenders convicted under the felony-murder rule); State v. Ali , 855 N.W.2d 235 , 258-59 (Minn. 2014) (noting the constitutionality of life sentences for juveniles convicted of felony murder); cf. Dillon , 194 Cal.Rptr. 390 , 668 P.2d at 700-01, 727 (holding a seventeen year-old's sentence of life imprisonment for felony murder was unconstitutional as applied where the offender fatally shot his victim out of fear for his life in the course of tryin

22018–2018
Brian K. Allison v. State of iowa green
iowa · 2018
12021–2021
State Ex Rel. Peacher v. Sencindiver green
wva · 1977
12018–2018
In re the Personal Restraint of Andress red
wash · 2002
12018–2018
State v. Bruegger green
iowa · 2009
12018–2018
Mullaney v. Wilbur green
scotus · 1975
12018–2018
Varnum v. Brien green
iowa · 2009
12017–2017
State v. Schuler green
iowa · 2009
12016–2016
State v. Amos Branch green
or · 1966
12006–2006

Statutes the citing opinions construe

IA § Iowa Code § 707.2 (29) IA § Iowa Code § 707.1 (16) IA § Iowa Code § 702.11 (14) IA § Iowa Code § 822.3 (13) IA § Iowa Code § 708.4 (9) IA § Iowa Code § 602.9206 (8) IA § Iowa Code § 690.2 (8) IA § Iowa Code § 711.1 (7) IA § Iowa Code § 702.13 (6) IA § Iowa Code § 702.18 (5) IA § Iowa Code § 708.1 (5) IA § Iowa Code § 708.6 (5)

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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