People v. Aaron
CourtMichigan Supreme Court
Full case namePeople of the State of Michigan v. Stephen J. Aaron
DecidedNovember 24, 1980 (1980-11-24)
Citation(s)299 N.W.2d 304; 409 Mich. 672
Case history
Appealed fromMichigan Court of Appeals
Court membership
Judges sittingKavanaghWilliamsColemanLevinFitzgeraldRyanMoody
Case opinions
Held: (1) Murder in Michigan is common-law murder; the elements of murder are established solely by case law. (2) Felony-murder requires malice equivalent to murder, is thus redundant, and is therefore abolished.
Decision byFitzgerald
ConcurrenceWilliams
Concur/dissentRyan

People v. Aaron, 299 N.W.2d 304 (1980), was a case decided by the Michigan Supreme Court that abandoned the felony-murder rule in that state.[1] The court reasoned that the rule should only be used in grading a murder as either first or second degree, and that the automatic assignment of the mens rea of the felony as sufficient for the mens rea of first degree murder was indefensible.[2]

Michigan is unique among states that have abolished the felony-murder rule entirely in doing so by judicial decision; this was acceptable because, unlike most other states, the felony-murder rule, and indeed the definition of murder itself, was entirely a common law offense, i.e. inherited from English judge-made common law.[3]

References

  1. Bonnie, R.J. et al. Criminal Law, Second Edition. Foundation Press, New York, NY: 2004, p. 858
  2. Bonnie, p. 859
  3. People v. Aaron, 299 N.W.2d 304, 319-320; 323-324 (Mich. 1980).
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