A man in Florida is serving the seventh year of a life sentence for a murder that was committed while he was asleep in his bed a mile and a half away. He was charged with murder because he loaned his car to someone who, prosecutors alleged, he knew intended to use it to commit a burglary with the likelihood of violence. The “felony murder” rule allows a murder charge against someone involved in another felony that resulted in someone’s death. It is part of a broader legal concept of criminal liability for other people’s actions, known as the “law of parties” in Texas. According to The Nation, every country with a legal system based on English common law has abolished the felony murder rule except for the U.S. In Texas, the law of parties remains an important feature of the criminal justice system.
Ryan Holle was convicted of first-degree murder in the death of an 18-year-old woman in Pensacola, Florida in March 2003. Prosecutors alleged that he loaned his car to his roommate and then went to bed. While he was asleep, the roommate and several other people drove to a house, where they intended to break in and steal marijuana from a safe. During the burglary, a woman in the house was killed.
The people directly involved in the burglary were charged with first-degree murder, burglary, and robbery. Prosecutors also charged Holle, who had reportedly made statements to police that he had heard his roommate and others talking about stealing the safe from the house and the possibility of violence. At trial, the prosecutor argued that Holle’s car was essential to the crime, that Holle knew what they intended to do, and that he loaned them his car for that purpose. Holle argued that he did not know why his roommate wanted the car, and that he had loaned the car to him many times before without incident. The jury convicted Holle of murder and sentenced him to life imprisonment without the possibility of parole.
Texas law allows a person to be held criminally liable for another person’s conduct if they are “criminally responsible” for that conduct. Tex. Pen. Code § 7.01(a). This may include causing another person to engage in criminal conduct, or encouraging or aiding another person in the commission of an offense. Tex. Pen. Code § 7.02(a). If, during an attempt to carry out a criminal conspiracy, as defined in § 15.02 of the Penal Code, a conspirator commits another felony, all of the conspirators may be charged with that felony. Id. at § 7.02(b). This is Texas’ version of the felony murder rule, although it can apply to any felony offense.
This aspect of the law of parties is controversial, since it allows the state to charge someone with a serious offense, as opposed to conspiracy or attempt, without having to prove intent to commit that offense. Other jurisdictions have discarded the rule in favor of direct proof of intent to commit the felony. In R. v. Martineau , 2 SCR 633, for example, the Supreme Court of Canada held that “the principles of fundamental justice” require “proof beyond a reasonable doubt of subjective foresight of death” to sustain a murder conviction.
For over 20 years, board-certified criminal defense attorney Michael J. Brown has fought for the rights of west Texas defendants charged with alleged state and federal offenses related to drugs, white collar crime, and other matters. To schedule a confidential consultation to discuss your case, please contact us today online or at (432) 687-5157.
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Photo credit: Jakub Schikaneder [Public domain], via Wikimedia Commons.