Palmer v. State

SULLIVAN, Justice,

concurring in part and dissenting in part.

The events that gave rise to this prosecution were horrendous and Palmer’s participation in them warrants sanction of the severest order. I fully concur in the majority’s affirmance of his convictions for kidnaping, attempted murder and conspiracy to commit escape. I respectfully suggest, however, that our murder8 and accomplice liability9 statutes do not permit a conviction for felony murder on these facts.

Four decades ago, Professor Morris wrote that “for centuries innocent persons and felons have been killed as the result of justified resistance to felonies of violence; in only a handful of such cases has it been even suggested that the surviving felons are guilty of murder.”10 Whether his analysis of legal *128history on this point was accurate, I do not know. But certainly such liability has been both imposed and rejected in many cases since his article appeared.11 A review of these materials indicates to me that the only proper way of resolving whether an Indiana defendant may be guilty of felony murder where the defendant’s fellow perpetrator was the person killed is by reference to the language of our statute.12

I do not believe that our statutes authorize the imposition of liability for murder where the defendant’s co-perpetrator is the victim.

Our felony murder statute provides: “A person who ... kills another human being while committing or attempting to commit ... kidnaping ... commits murder, a felony.” Ind.Code § 35-42-1-1. Palmer here did not kill another human being; his co-perpetrator was killed by a law enforcement official. Under the terms of the felony murder statute, Palmer is not guilty of felony murder.

Our accomplice liability statute provides: “A person who knowingly or intentionally aids ... another person to commit an offense commits that offense.” Ind.Code § 35-41-2-4. A person can be liable for felony murder for aiding another person in the commission thereof. But because Palmer’s co-perpetrator did not commit felony murder, Palmer cannot be found to have aided in committing that offense. Under the terms of the accomplice liability statute, Palmer is not guilty of felony murder.

I respectfully suggest that none of the several eases from this Court that the majority cites in support of its position are on point. Each involves a situation in which the defendant himself inflicted physical injury on the victim who later died. The question in each was whether an intervening cause absolved the defendant of liability. Indeed, the proposition of law for which these cases stand is articulated in one of the cases as follows: “An individual who inflicts injury upon another is deemed by law to be guilty of homicide if the injury contributed mediately or immediately to the death of that other person.” Sims v. State, 466 N.E.2d 24, 25 (Ind.1984) (emphasis supplied). Here, in contrast, Palmer did not inflict the injury upon Williams that caused Williams’s death.

I would vacate Palmer’s conviction for murder. However, he would remain convicted of kidnaping, attempted murder and conspiracy to commit escape. I fully agree that consecutive sentences are justified here, making Palmer eligible for 108 years in prison (compared to the 118 year sentence imposed by the trial court).

SHEPARD, C.J., concurs.

. Ind.Code§ 35-42-1-1.

. Ind.Code § 35-41-2-4.

. Norval Morris, The Felon’s Responsibility for the Lethal Acts of Others, 105 U. Pa. L.Rev. 50, 66 (1956).

. See, e.g., Martin J. McMahon, Annotation, Application of Felony-Murder Doctrine Where Person Killed was Co-Felon, 89 A.L.R.4th 683 § 11 (1991); Erwin S. Barber, Annotation, Criminal Liability Where Act of Killing is Done by One Resisting Felony or Other Unlawful Act Committed by Defendant, 56 A.L.R.3d 239 § 13 (1974).

. See State v. Martin, 119 N.J. 2, 22-26, 573 A.2d 1359, 1370-71 (N.J.1990) (after court held in State v. Canola, 73 N.J. 206, 374 A.2d 20 (1977), that one felon could not be held liable for the death of a co-felon caused by one resisting the commission of the felony, the legislature eliminated the statutory requirement that the death be caused by one of the felons and provided that the liability requirement was satisfied if the death was caused by "any person”); State v. Thai Do Hoang, 243 Kan. 40, 755 P.2d 7, 10 (1988) ("Review of case law of other jurisdictions (on this issue] is not particularly helpful herein by virtue of the wide variety of the statutory language employed in the definitions of felony murder.”); Norval Morris, supra ("[I]f the view be that justice and social utility are to be served by imposing on felons criminal liability for murder where the killing is the result of defensive and retaliatory force that they have precipitated, it is submitted that this is a step more appropriately to be taken by the legislature than by the judiciary.”).