State v. Martin

119 N.J. 2, 573 A.2d 1359 (1990)

 

RULE:

Correct charges are essential for a fair trial. A charge is a road map to guide the jury, and without an appropriate charge a jury can take a wrong turn in its deliberations. Thus, the court must explain the controlling legal principles and the questions the jury is to decide. So critical is the need for accuracy that erroneous instructions on material points are presumed to be reversible error. 

FACTS:

Defendant appealed his convictions for murder, felony murder, arson and aggravated arson in the trial court after he had set a fire in an apartment during a party when he was asked to leave. The appellate court affirmed his convictions and defendant sought review, contending that the evidence was insufficient to establish knowing and purposeful murder under N.J. Stat. Ann. § 2C: 11-3a(1) and (2), and that the trial court erred by not adequately instructing the jury on causation under N.J. Stat. Ann. § 2C: 2-3. The court determined that sufficient evidence existed in the record for a jury to conclude beyond a reasonable doubt that the defendant had committed murder. However, the court, after an extensive analysis of causation, reversed finding plain error.

ISSUE:

Can defendant be held liable for murder or felony murder if the victim's death was not the probable consequence of his actions?

ANSWER:

No.

CONCLUSION:

The trial court failed to instruct the jury that defendant would not be liable for the felony murder of the victim if her death was too remote, accidental in its occurrence, or too dependent on another's volitional act to have a just bearing on the defendant's culpability, and that that he would not be liable for murder if the victim's death was not the probable consequence of the defendant's actions.

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