People v. Patterson case brief

People v. Patterson case brief summary
778 P.2d 549 (1989)

CASE SYNOPSIS

The people appealed a judgment of an appellate court (California), which affirmed the trial court's dismissal of the second degree felony-murder charges against defendant.

CASE FACTS
Defendant was charged with murder under the second degree felony-murder doctrine for violating Cal. Health & Safety Code § 11352 when he furnished cocaine to a person who died as a result of ingesting it. The trial court dismissed the murder charges against defendant because the second degree felony-murder doctrine was inapplicable to defendant's case and the appellate court affirmed.

DISCUSSION

• The court reversed and remanded the judgment that held as a matter of law that the second degree felony-murder doctrine did not apply to defendant. 
• The court held that in determining whether the felony was inherently dangerous, the court should have looked to the elements of the felony in the abstract, not the particular facts of the case. 
• The inquiry into inherent dangerousness should have focused on the felony of furnishing cocaine, and not § 11352 as a whole. 
• A felony was inherently dangerous to life when there was a high probability that its commission would result in death. 
• The second degree felony-murder doctrine acts as a substitute for malice; thus, when a defendant commits a felony inherently dangerous to life malice need not be shown to convict defendant of murder.

CONCLUSION
The court reversed and remanded the judgment because in determining whether the felony was inherently dangerous for the purpose of the second degree felony-murder doctrine, the court should have looked to the elements of the felony in the abstract, not the particular facts of the case. Further, a felony was inherently dangerous to life when there was a high probability that its commission would result in death.

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