transferred intent doctrine (New Mexico) · Go Syfert
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transferred intent doctrine in New Mexico

7 New Mexico opinions name it 2 courts 1976–2020 0 in the last five years

The cases below were cited by New Mexico 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 (4)

CaseFollowedCited
State v. Feketegreen
nm · 1995 · cited in 3 New Mexico opinions naming this issue, 1999–2020
2 sentences

2009“When a criminal statute 17 matches specific intent with a specific victim, the doctrine of transferred intent 18 protects an unintended victim.” Id. (providing as an example the specific intent crime 19 of murder where “a defendant, while intending to kill one person, accidentally kills 13 1 an innocent bystander or another unintended victim”) (internal quotation marks 2 omitted).

1999See State v. Fekete, 120 N.M. 290, 296 , 901 P.2d 708, 714 (1995) (“The doctrine of transferred intent is a legal fiction that is used to hold a defendant criminally liable to the full extent of his or her criminal culpability.”); People v. Czahara, 203 Cal.App.3d 1468 , 250 Cal.Rptr. 836, 838-39 (1988) (stating that “[t]he transferred intent rule serves to ensure that [a defendant] is punished to the full extent of his [or her] culpability” and stating that the transferred intent rule is inapplicable if the intended victim is killed because the killer’s punishment can be commensurate to his o

13
People v. Blandgreen
cal · 2002 · cited in 2 New Mexico opinions naming this issue, 2018–2018
2 sentences

2018"Contrary to what its name implies, the transferred intent doctrine does not refer to any actual intent that is capable of being used up." People v. Bland , 28 Cal.4th 313 , 121 Cal.Rptr.2d 546 , 48 P.3d 1107 , 1113 (Cal. 2002) (internal quotation marks and citation omitted).

2018"Contrary to what its name implies, the transferred intent doctrine does not refer to any actual intent that is capable of being used up." People v. Bland , 28 Cal.4th 313 , 121 Cal.Rptr.2d 546 , 48 P.3d 1107 , 1113 (Cal. 2002) (internal quotation marks and citation omitted).

12
Juarez v. Stategreen
texapp · 1994 · cited in 1 New Mexico opinions naming this issue, 1999–1999
1 sentence

1999See State v. Fekete, 120 N.M. 290, 296 , 901 P.2d 708, 714 (1995) (“The doctrine of transferred intent is a legal fiction that is used to hold a defendant criminally liable to the full extent of his or her criminal culpability.”); People v. Czahara, 203 Cal.App.3d 1468 , 250 Cal.Rptr. 836, 838-39 (1988) (stating that “[t]he transferred intent rule serves to ensure that [a defendant] is punished to the full extent of his [or her] culpability” and stating that the transferred intent rule is inapplicable if the intended victim is killed because the killer’s punishment can be commensurate to his o

11
People v. Czaharagreen
calctapp · 1988 · cited in 1 New Mexico opinions naming this issue, 1999–1999
2 sentences

1999See State v. Fekete, 120 N.M. 290, 296 , 901 P.2d 708, 714 (1995) (“The doctrine of transferred intent is a legal fiction that is used to hold a defendant criminally liable to the full extent of his or her criminal culpability.”); People v. Czahara, 203 Cal.App.3d 1468 , 250 Cal.Rptr. 836, 838-39 (1988) (stating that “[t]he transferred intent rule serves to ensure that [a defendant] is punished to the full extent of his [or her] culpability” and stating that the transferred intent rule is inapplicable if the intended victim is killed because the killer’s punishment can be commensurate to his o

1999See State v. Fekete, 120 N.M. 290, 296 , 901 P.2d 708, 714 (1995) (“The doctrine of transferred intent is a legal fiction that is used to hold a defendant criminally liable to the full extent of his or her criminal culpability.”); People v. Czahara, 203 Cal.App.3d 1468 , 250 Cal.Rptr. 836, 838-39 (1988) (stating that “[t]he transferred intent rule serves to ensure that [a defendant] is punished to the full extent of his [or her] culpability” and stating that the transferred intent rule is inapplicable if the intended victim is killed because the killer’s punishment can be commensurate to his o

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (8)

CaseCitedYears
State v. Carpio green
nm · 1921
2 sentences

1985State v. Carpio, 27 N.M. 265 , 199 P. 1012 , 18 A.L.R. 914 (1921).

1985State v. Carpio, 27 N.M. 265 , 199 P. 1012 , 18 A.L.R. 914 (1921).

11985–1985
State v. Sanders green
nmctapp · 1979
2 sentences

1985Moreover, the standard of review for determining if instructions which deviate from the Uniform Jury Instructions constitute reversible error is “the slightest evidence of prejudice.” State v. Sanders, 93 N.M. 450, 451 , 601 P.2d 83 (Ct.App. 1979).

1985Moreover, the standard of review for determining if instructions which deviate from the Uniform Jury Instructions constitute reversible error is “the slightest evidence of prejudice.” State v. Sanders, 93 N.M. 450, 451 , 601 P.2d 83 (Ct.App. 1979).

11985–1985
People v. Smith green
illappct · 1981
2 sentences

1985People v. Smith, 94 Ill.App.3d 969 , 50 Ill.Dec. 296 , 419 N.E.2d 404 (1981); Kitchens v. State, 149 Tex.Cr.R. 135 , 192 S.W.2d 449 (1946).

1985People v. Smith, 94 Ill.App.3d 969 , 50 Ill.Dec. 296 , 419 N.E.2d 404 (1981); Kitchens v. State, 149 Tex.Cr.R. 135 , 192 S.W.2d 449 (1946).

11985–1985
Kitchens v. State green
texcrimapp · 1946
2 sentences

1985People v. Smith, 94 Ill.App.3d 969 , 50 Ill.Dec. 296 , 419 N.E.2d 404 (1981); Kitchens v. State, 149 Tex.Cr.R. 135 , 192 S.W.2d 449 (1946).

1985People v. Smith, 94 Ill.App.3d 969 , 50 Ill.Dec. 296 , 419 N.E.2d 404 (1981); Kitchens v. State, 149 Tex.Cr.R. 135 , 192 S.W.2d 449 (1946).

11985–1985
State v. Ochoa green
nm · 1956
1 sentence

1976This instruction conforms with the doctrine of transferred intent as stated in State v. Carpio, supra, and State v. Ochoa, supra. Instructions are to be read and considered as a whole and when so considered they are proper if they fairly and accurately state the applicable law.

11976–1976
Padilla v. State green
nm · 1974
1 sentence

1976State v. Rushing, 85 N.M. 540 , 514 P.2d 297 (1973); State v. Rhea, 86 N.M. 291 , 523 P.2d 26 (Ct.App.) cert. denied, 86 N. M. 281, 523 P.2d 16 (1974).

11976–1976
State v. Rhea green
nmctapp · 1974
2 sentences

1976State v. Rushing, 85 N.M. 540 , 514 P.2d 297 (1973); State v. Rhea, 86 N.M. 291 , 523 P.2d 26 (Ct.App.) cert. denied, 86 N. M. 281, 523 P.2d 16 (1974).

1976State v. Rushing, 85 N.M. 540 , 514 P.2d 297 (1973); State v. Rhea, 86 N.M. 291 , 523 P.2d 26 (Ct.App.) cert. denied, 86 N. M. 281, 523 P.2d 16 (1974).

11976–1976
State v. Rushing green
nm · 1973
2 sentences

1976State v. Rushing, 85 N.M. 540 , 514 P.2d 297 (1973); State v. Rhea, 86 N.M. 291 , 523 P.2d 26 (Ct.App.) cert. denied, 86 N. M. 281, 523 P.2d 16 (1974).

1976State v. Rushing, 85 N.M. 540 , 514 P.2d 297 (1973); State v. Rhea, 86 N.M. 291 , 523 P.2d 26 (Ct.App.) cert. denied, 86 N. M. 281, 523 P.2d 16 (1974).

11976–1976

Statutes the citing opinions construe

NM § N.M. Stat. § 30-2-1 (3) NM § N.M. Stat. § 30-28-1 (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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