State v. Thompson

The Facts

Defendant charged with first degree murder.  Defendant originally climbed through a window of a church and attempted to steal a box containing $550.  When leaving, the pastor grabbed the victim and a scuffle ensued.  Defendant threw the pastor to the floor and hit him twice in the face even after he fell to the floor.  The pastor later bled to death as a result of lacerations to his face.  The defendant was later stopped with an iron rod in his car, which the coroner testified caused the lacerations to his face.  However, experts and the coroner testified that if the rod had been used “they would have expected more tissue to be found on this weapon.”  Examination reveals only a small amount of blood on the rod and no human tissue.  Defendant testified at trial that he did not use the weapon against the pastor; that he only used his fists.  He also testified that he did not intend to kill the pastor and that he was still breathing when he left the church.

Procedural History

Defendant pled guilty at trial and sentenced to life imprisonment.  Defendant appealed.  Court must review in light most favorable to the prosecution.

Relevant Statute

“First degree murder is the killing of a human being: (1) When the offender has specific intent to kill or to inflict great bodily harm.”

The Issue

Whether the source injury (such as a rod as opposed to a fist) can supply evidence of specific intent required for conviction or whether the severity of injury can alone sufficiently prove specific intent.

The Holding/Reasoning

The severity of injuries in this case is sufficient to demonstrate the specific intent to cause great bodily injury.  “Specific intent is the state of mind which exists when the circumstances indicate that the offender actively desired the prescribed criminal consequences to follow his act or failure to act.”  Specific intent can be proven by direct evidence of inferred evidence (circumstantial evidence).  The defendant’s own testimony that he struck the pastor while he was on the floor demonstrates the specific intent required to show intent to cause great bodily harm.  The fact that evidence suggests he did not use the rod is irrelevant.  Viewed in light most favorable to the prosecution, the jury at trial could have reasonably rejected the defendant’s own statement that he did not intend to kill the pastor based on the evidence.  Conviction upheld.

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