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People v Aaron
S. Ct. Mich. 1980
Author:- Sam Biers
Facts: Aaron had a negative judgment for second-degree murder returned.
Issue: Does Michigan have a common-law Murder Rule and if so should it continue in perpetuity?
What mens rea is required to support a conviction under Michigan’s first degree murder statute?
Holding: Michigan has no statutory felony-murder rule which allows the mental element of murder to be satisfied by proof of the intention to commit the underlying felony.
Procedure: On appeal from trial court, and State Court of Appeals, judgement against defendant for second-degree murder.
Reasoning: In order to convict a defendant of murder it must be shown that he acted with intent to kill or to inflict great bodily harm or with a wanton and willful disregard of the likelihood that the natural tendency of his behavior is to cause death or great bodily harm. Malice must always be submitted to the jury.
Plaintiff might argue: The defendant’s actions to willfully commit a heinous felony, not murder, but which fits an element of murder, and a murder results, would likewise have proven the necessary intent element of murder.
Defendant : Intent is an element which must be proven by the state for each and every crime listed within the state’s charge and should be left to the jury to decide as a legal fact. This ruling is inconsistent with law and the application of previous decision.
Rule: Malice = 1) intention to kill, 2) the intention to commit great bodily harm, or 3) the wanton and willful disregard of the likelihood that the natural tendency of defendant’s behavior is to cause death or great bodily harm.