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Law School Case Brief

People v. Geiger - 10 Mich. App. 339, 159 N.W.2d 383 (1968)

Rule:

In determining whether a person who has killed another without meaning to kill him is guilty of murder or manslaughter, the nature and extent of the injury or wrong that was actually intended must usually be of controlling importance. It is not necessary in all cases that one held for murder must have intended to take the life of the person he slays by his wrongful act. It is not always necessary that he must have intended a personal injury to such person. But it is necessary that the intent with which he acted shall be equivalent in legal character to a criminal purpose aimed against life. Generally, the intent must have been to commit either a specific felony, or at least an act involving all the wickedness of a felony. And if the intent be directly to produce a bodily injury, it must be such an injury as may be expected to involve serious consequences, either periling life or leading to great bodily harm. There is no rule recognized as authority that will allow a conviction of murder where a fatal result was not intended, unless the injury intended was one of a very serious character that might naturally and commonly involve loss of life or grievous mischief.

Facts:

Defendant was convicted for manslaughter. It appears that defendant confronted his estranged wife in the parking lot of a bar. Defendant forced the victim into her car and drove away. The victim had been struck about the face and body by a blunt object such as a hand or a fist. Sometime after the beating, the victim attempted to vomit and had choked to death. 

Issue:

Is a jury instruction that the prosecutor had to establish insanity by fair preponderance of the evidence proper when the intent to kill was evident?

Answer:

No.

Conclusion:

The court reversed and remanded. An assault by blows without a weapon could, under certain circumstances, permit a jury to infer intent to kill. The injuries were "reasonably calculated to cause death" and the wounds "contributed mediately or immediately to the death." The trial court erred by instructing the jury that the prosecutor had to establish insanity by a "fair preponderance of the evidence" instead of "beyond a reasonable doubt."

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