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People v. Aaron | 299 N.W.2d 304 (1980)

Under the felony murder rule, a defendant may be convicted of murder if the defendant kills another during the commission or attempted commission of a predicate felony. The purpose of the rule is to deter those who commit certain felonies from killing by holding them strictly liable for any killing committed during the commission or attempted commission of the felony. But do all states follow this rule? In People versus Aaron, the court reexamined the felony murder rule and its application in a case involving three felony murder convictions.

Between nineteen seventy seven and nineteen eighty, three criminal defendants were convicted in Michigan of felony murder.

First, Robert Thompson was convicted of first degree felony murder following a death that occurred during an armed robbery. At trial, the judge instructed the jury that the prosecution didn’t need to prove malice, which is the intent to kill. Rather, all the prosecution had to prove was that Thompson intended to rob the store to be convicted of felony murder. Following his conviction, Thompson appealed, and the court of appeals reversed, holding that the trial court erred in failing to instruct the jury on the element of malice in the felony murder charge.

Second, Jessie Wright was convicted of first degree felony murder after he set fire to a dwelling, causing the deaths of two people. At trial, the judge instructed the jury that the prosecution only had to prove that the deaths occurred during the commission of the arson to prove felony murder. Following his conviction, Wright appealed. The court of appeals reversed, holding that the court erred in removing the element of malice from the jury’s consideration.

Third, Stephen Aaron was convicted of first degree felony murder following a homicide committed during an armed robbery. At trial, the jury was instructed that they could find Aaron guilty of first degree murder if they found he killed the victim during the commission or attempted commission of an armed robbery. In addition, Aaron requested a jury instruction on lesser included offenses, which the court refused. Following his conviction, Aaron appealed, and the court of appeals affirmed. Aaron appealed to the Michigan Supreme Court, which remanded to enter judgment on the lesser included second degree murder offense and for resentencing.

Subsequently, Aaron filed an application for reconsideration and leave to appeal with the Michigan Supreme Court, which the court granted. The court consolidated the three cases.

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