State v. Martin

Supreme Court of New Jersey, 1990.


  • D was asked to leave a party in an apartment and at the bottom of the landing of the building he set a paper bag on fire that contained trash that the D found in the hallway by the apartment’s door
  • State says that fire was being set by setting up kerosene.
  • D did not think that it would spread or catch onto anything.  “I didn’t mean to hurt nobody”.
  • The building caught on fire and everyone escaped except Barbara Quartz, who had fallen asleep after drinking at the party.  She died of asphyxiation due to smoke inhalation and carbon monoxide inhalation.

Procedural History:  Defendant appealed the order of the Superior Court (New Jersey) that affirmed his convictions for murder, felony murder, arson and aggravated arson, contending that the evidence was insufficient to establish knowing and purposeful murder under N.J. Stat. Ann. § 2C:11-3a(1) and (2), and that the trial court erred by not adequately instructing the jury on causation under N.J. Stat. Ann. § 2C:2-3.

Issue: 1. Did sufficient evidence exist in the record for a jury to conclude that D had committed murder?  2. Did the court properly instruct the jury on causation?

Holding: 1. The court determined that sufficient evidence existed in the record for a jury to conclude beyond a reasonable doubt that the defendant had committed murder.  2. However, court did not properly instruct the jury.  (see reasoning)


  • Trial court failed to instruct the jury that defendant would not be liable for the felony murder of the victim if her death was too remote, accidental in its occurrence, or too dependent on another’s volitional act to have a just bearing on the defendant’s culpability, and that that he would not be liable for murder if the victim’s death was not the probable consequence of the defendant’s actions.
  • This is the court’s interpretation of “probable consequence”

Disposition:  Because the trial court did not adequately charge the jury on causation under N.J. Stat. Ann. § 2C:2-3, the court reverses the judgment of conviction for murder, and remands the cause to the Law Division.

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